Practice Area · 7 Articles

Tax Disputes: Statistics, Defense, Practice

In-depth analyses of tax audits, challenging tax acts, Federal Tax Service (FTS) interrogations, and Article 199 of the Russian Criminal Code. Arbitrazh court statistics for 2024-2025.

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Field Tax Audit in 2025-2026: Statistics, Pre-Trial Maneuvers, and Tax Reconstruction

A complete breakdown of field tax audits (FTA) in 2024-2026: 98% success rate for the tax authority, average assessment of RUB 94-120 million, pre-trial appeals, tax reconstruction, and viable defense strategies.

· ~20 min · 31k characters
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02 · From the Author's Notes
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Tax Disputes in 2024-2025: What Arbitrazh Court Statistics Reveal

Analysis of judicial practice in tax disputes from 1998 to 2025: 84.6% of rulings favor the FTS, 4.79% success rate by monetary value, the statistical paradox, and four principles of business defense.

84.6%4.79%RUB 65M
· ~19 min · 29k characters
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Federal Tax Service Interrogation in 2025-2026: Procedure, Pre-Existing Knowledge, and Effective Tactics

An objective analysis of FTS interrogations: Article 90 of the Russian Tax Code, Article 51 of the Constitution, witness rights, standard scenarios, 2024-2025 practice, and actionable steps.

· ~22 min · 33k characters
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Avoiding Imprisonment During Tax Maneuvers: Ten Years Later

A remake of the 2015 article: new thresholds of RUB 18.75/56.25 million, initiation procedures via the FTS since 2022, actual sentencing statistics, and how to avoid the criminal prosecution corridor...

· ~22 min · 34k characters
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06 · Related Sections
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Challenging a Tax Audit Act in 2026: A Step-by-Step Guide

A practical guide to challenging a tax audit act. Deadlines, articles of the Russian Tax Code, preparation of objections, and filing an appeal with the Regional Tax Office (UFNS).

· ~7 min · 11k characters
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08 · TAXES
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Criminal Liability for Tax Offenses: Article 199 of the Russian Criminal Code

Criminal liability for tax offenses: elements of Articles 199, 199.1, and 199.2 of the Russian Criminal Code, threshold amounts, defense strategies, and interaction with tax audits.

~30 min · 46k characters
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10 · TAXES
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Tax Audit: Taxpayer Rights and Defense Strategy

Desk and field tax audits: rights, deadlines, procedure for challenging an act, and defense strategy. Articles 88-101 of the Russian Tax Code. Counsel with 20 years of experience.

~30 min · 46k characters
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