Issues of improving the application boundaries of the "minimum price" mechanism in the methodology for determining the tax base in the sale of sand-and-gravel products

Abstract

This article examines the methodological boundaries of applying a minimum selling price mechanism to sand-and-gravel mixtures for tax-base determination. A methodological approach is proposed under which the minimum price rule applies only to the primary sale of extracted and unprocessed sand-and-gravel mixture by a subsoil user or quarry operator to the first purchaser. The article also substantiates the separation of the quarry product value from separately documented transportation, loading and service charges, cross-verification of cubic-meter volumes through electronic invoices, waybills and measurement records, and documentary control of returns and adjustments. The proposed framework is designed to prevent both unjustified erosion and artificial expansion of the tax base, ensure consistent interpretation of the rule and reduce tax disputes.