Such conclusions were reached by experts of the A.I.T.T. analytic center, who analyzed management reporting, the history of bank borrowing, and other information available in open sources. Moreover, in Russia, the group probably did not pay more than $ 50 million to budgets of different levels over the last three years, despite the fact that over the same period, the companies included in it have contributed over 40 million euros in taxes to the Latvian budget .
The authors of the study of the financial condition of the group, the Russian analytical center AIST, claim that between 2014 and 2018 the negative net assets of Uralchem reached 113 billion rubles, and the net loss for the same period amounted to 96 billion rubles. Among the reasons that could lead the company to a pre-default state are borrowings from foreign and Russian banks in the amount of 590 billion rubles spent on gaining control over the public joint-stock company Uralkali's loss. According to the study, the activities of the group’s enterprises are unprofitable: according to the results of 2018, Uralkali’s loss was 4.91 billion rubles, Uralchem’s loss was 40.2 billion rubles. The value of the pledged shares does not correspond to the debt burden of holding enterprises. If the group fails to restructure the debt, bankruptcy may occur already at the end of 2019, when the maturity of Uralkali's debt to Sberbank comes.
If you believe the study, the Latvian trading companies are actively involved in the structure of the group, thanks to which the "profit center" of Uralchem and Uralkali has long been outside of Russia. Its authors argue that in the group that includes both enterprises, transfer pricing is used when selling products abroad, due to which most of their profits are redistributed in favor of companies registered in countries with milder tax regimes, in particular Latvia. According to the study, more than 90% of the capital of the Uralchem group belongs to organizations registered in offshore zones. A controlling stake in Uralkali in the amount of 54.8% is quasi-treasury (the shares are on the balance sheet of a 100% subsidiary of Uralkali-Technologiya), the rest is distributed between partners Dmitry Mazepin (19.9% through the ownership of JSC UCC Uralchem ) and Dmitry Lobyak (20.29% through an offshore jurisdiction company).
One of the key findings of the study is that Uralchem UHC JSC and Uralkali PJSC use transfer pricing (TP) when selling products, which allows you to redistribute the total profit of a group of companies in favor of multinational companies located in countries with lower taxes. The use of transfer pricing through the sale of products at discounted prices that are significantly different from market prices through transactions with related foreign companies is one of the most common schemes for minimizing paid taxes.
The authors argue that when determining prices with affiliates - SIA Uralchem Trading and SIA Uralkali Trading, the companies of JSC Uralchemical and Chemical Combine Uralkali and PJSC Uralkali use the method of comparable profitability (one of the transfer pricing methods). According to the study, only for Uralkali PJSC FTS for 2012, it revealed the amount of the unaccounted tax base for corporate income tax in the amount of 6.32 billion rubles. So, in 2018, Uralkali lost in court a dispute with the Federal Tax Service about additional taxes for 2012 in the amount of 980 million rubles. The Federal Tax Service considered that Uralkali underestimated the income tax base through a deal with related parties.
It follows from the study that starting in 2014, Uralkali actually stopped paying dividends and significantly reduced income tax payments, despite the fact that the company is the key for the Urals Federal District. So, for five years from 2014 to 2018, only 13.5 billion rubles were paid. income tax. Before the transfer of control over the enterprise to the structures of Dmitry Mazepin, for the three years from 2011 to 2013, 24.5 billion rubles were paid. income tax. For comparison: that Lukoil-Perm, which is also the largest enterprise in the Perm Territory, paid four times more profit tax to the budget for the five years from 2014 to 2018 - 53.5 billion rubles. This is especially striking in view of the fact that Uralchem, in comparison with other companies in the mineral fertilizer market, has the highest revenue and profit from sales. But since the end of 2013, the company paid only 2.7 billion rubles in taxes on profits and dividends ...
According to experts, reflected in the mentioned study: the total profit of four Latvian enterprises of Dmitry by the end of 2017 is estimated at $ 52 million, the estimated value of companies is $ 503.5 million, of which 90% or $ 458.4 million is the estimated value SIA Uralchem Trading. According to the State Revenue Service (SRS), published on the Latvian Lursof website (a database of registered enterprises, similar to the Russian register), the total amount of tax payments to the state budget by SIA Uralchem Trading for 3 years (2016-2018) amounted to 13 million euros . According to the results of three years, payments to the budget by SIA Uralkali Trading amounted to more than 17 million euros, of which more than 10 million in 2017.
Dmitry Mazepin is connected not only with commercial interests with Latvia: since 2012, a Russian businessman has actively invested in the purchase of expensive Latvian assets, including: the Latvian football club - Skonto FC (Riga's "Skonto" - the most famous football club in Latvia); hotels in Jurmala (Dubulti), located next to the residence of the President of Latvia; supposedly even gay clubs in Riga - “Golden” and “XXL”. According to open sources, Dmitry Mazepin also sponsors the Concord Center party, the leader of which is the former mayor of Riga, Neil Ushakov.