Previously, disputes with tax authorities remained in the realm of financial additional assessments and fines, but now the situation has changed dramatically. 2025-2026 - this is a time when risks have shifted to the criminal sphere. In fragmentation cases (Articles 199, 173.1, 173.2 of the Criminal Code of the Russian Federation), real sentences are handed down, including imprisonment.

Why is this especially dangerous now?

• Established practice of the Federal Tax Service. Tax authorities have learned to build an evidence base so that everything is visible as if on the palm of your hand: interconnection, shared offices, personnel, counterparties, management from a single center.

• AI analytics. The state actively uses technology to automatically identify chains of related companies. What used to be a "gray area" is now a clear signal for inspection.

• Focus on intent. Key criterion: the purpose of creation. If the main goal was to obtain an unjustified tax benefit (especially VAT), rather than actual business conduct, then it is immediately a crime.

• Liability across the entire vertical. Not only "nominees" are at risk, but also actual beneficiaries, general directors, and chief accountants as organizers and accomplices.

What is considered fragmentation in 2026?

This is not just several individual entrepreneurs among relatives or several LLCs owned by one person. It refers to creating a network of legally independent but actually unified companies to:
1) Artificially understate turnover for the simplified tax system (USN)
2) Unjustifiably reclaim VAT
3) Understate income tax by "diluting" the base

What I recommend paying attention to:

Audit of the structure. Do you have several legal entities in the same field? Do they have real economic independence (at least different management centers)?

Analysis of document flow. Do all contracts and primary documents reflect actual business transactions? Or are they formal?

Assessment of business purposes. Can you clearly explain to an inspector the economic rationale for each legal entity's existence, apart from tax reasons?

Check for interdependence. Are the directors and founders "mass" or employees of each other?

In the current reality, the state has made combating fragmentation and tax evasion one of the main goals of fiscal policy. If you have doubts or understand that your structure may fall under fragmentation criteria, do not wait for guests, but "whiten" yourself or prepare for inspections and questions.