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

What a Field Tax Audit Is in Simple Terms

A field tax audit (FTA) is a form of tax control wherein inspectors examine a company's activities for a period of up to three preceding years, either by visiting the premises or by requesting all documents. The outcome is documented in an act, followed by a decision on holding (or not holding) the taxpayer liable. At each stage, the law provides opportunities for objections and appeals.

A field audit differs from a desk audit in three main parameters.

Depth. A desk audit verifies a single tax return for one period. An FTA covers all taxes over three years, or a single tax over three years (a thematic FTA).

Duration. A desk audit takes three months from the date the return is filed. An FTA takes two months, with the possibility of extension to four, and in exceptional cases, to six months.

Effectiveness. A desk audit results in additional assessments in 4-5% of cases. An FTA does so in 98%.

Finally, and most importantly. An FTA does not occur by chance. If it has been scheduled, it means the inspectorate has already conducted a pre-investigation inquiry, estimated the volume of potential assessments, and deemed the audit profitable for the budget. Thus, by the time the decision on an FTA is received, the inspectorate already has an approximate figure of the assessment. The task is to prevent them from reaching these amounts or to limit their size.

Chronology of Tightening: What Changed from 2018 to 2025

The evolution of field control is not a matter of random fluctuations, but the result of consistent efforts by the FTS to increase efficiency.

2018-2020. Reduction in quantity alongside an increase in quality. The FTS transitions to a risk-oriented approach. The number of FTAs drops from tens of thousands per year to a few thousand. However, the inspectorate prepares seriously for each audit: pre-investigation analysis, ASK NDS-2 and ASK NDS-3, and analytical systems for corporate income tax. The auditor does not receive a "random" company, but one from which, according to preliminary calculations, no less than RUB 30-50 million can be recovered.

2021. FTS Letter No. BV-4-7/3060@ of March 10, 2021. The possibility of tax reconstruction is recognized—but under strict conditions. This will be detailed below.

2022-2023. Stabilization at a high level. Approximately 4,000-5,000 FTAs per year nationwide. Success rate: 97-98%. Average assessments are growing. In 2023, the national average was RUB 63 million per audit.

2024. 4,495 FTAs conducted. Of these, 4,397 resulted in assessments. Success rate: 97.8%. Average assessments: RUB 65 million in Russia, RUB 101 million in Moscow, RUB 130 million in St. Petersburg.

Q1 2025. 1,148 audits, 1,131 with assessments. Success rate: 99%. Average assessment in Russia: RUB 79 million (+25% compared to the same period in 2024). In Moscow: RUB 115-120 million (+31% compared to Q1 2024).

H1 2025. The average assessment in Moscow reached its highest level since 2018—RUB 120.68 million per FTA.

9 months of 2025. 3,841 audits conducted in the Russian Federation, 3,768 with assessments. In Moscow: 1,356 audits, 1,323 with assessments. Success rate: 98%. The number of FTAs in the Russian Federation grew by 20% compared to the same period in 2024, and in Moscow by 45%.

2025 overall. According to FTS data from Vedomosti reviews: approximately 5,400 FTAs completed, compared to 4,900 in 2024. Budget revenues from FTAs increased by 24%—to RUB 186 billion. Assessments following FTAs totaled RUB 150.6 billion (a 15% increase). Over 80% of all assessments traditionally stem from VAT and corporate income tax.

According to Pravovest-Audit: in 2025, the average assessment in the Russian Federation was RUB 94 million. In Moscow: RUB 120 million+. In St. Petersburg: approximately RUB 130-140 million.

Sources: pravovest-audit.ru/nashi-statii-nalogi-i-buhuchet/nalogovaya-realnost-v-tsifrakh-i-faktakh/, vedomosti.ru/economics/articles/2026/04/29/1193850-postupleniya-v-byudzhet-ot-viezdnih-nalogovih-proverok-virosli, dolgiplus.ru/blog/biznes-i-finansy/statistika-vyezdnyh-nalogovyh-proverok-kuda-smeschaetsya-fokus-fns.

The trend is unequivocal. Fewer audits—higher amounts. Fewer misses—greater precision.

12 Criteria the FTS Uses to Select for an FTA

The concept of the field tax audit planning system was approved by FTS Order No. MM-3-06/333@ of May 30, 2007, and is regularly updated. All 12 criteria are public. Any business owner can conduct a self-check.

1. Low tax burden. The ratio of taxes paid to revenue is below the industry average. The FTS annually publishes industry average indicators on nalog.gov.ru.

2. Losses for two or more years. Especially if competitors in the same industry are reporting profits.

3. High share of VAT deductions. If over 12 months the share of deductions exceeds 89% of the accrued VAT, or the regional average.

4. Expenses growing faster than income. Expenses increasing more rapidly than revenue—an indicator of artificial inflation.

5. Low salaries. The average monthly salary of employees is below the industry average in the constituent entity of the Russian Federation.

6. Approaching the limits of special tax regimes. If under the simplified taxation system (USN) income approaches RUB 60 million or the threshold for fixed assets, or under the patent taxation system (PSN) approaches revenue and employee limits, the inspectorate will check for artificial business splitting.

7. Low profitability. Significantly below the industry average—a reason for scrutiny.

8. Chain of counterparties. Multiple intermediaries between the manufacturer and the final buyer, especially when the economic rationale is questionable.

9. Ignoring tax authority requests. Failure to comply with demands to provide documents or information.

10. Migration between inspectorates. Frequent changes of address involving a transfer to another tax authority—a standard sign of evading an audit.

11. Transactions with fly-by-night companies. Connections with entities exhibiting characteristics of 'technical' counterparties (shell companies).

12. Financial and economic activities with high tax risk. A general criterion under which the inspectorate can classify almost anything—but primarily business splitting schemes, the use of shell companies, and aggressive optimization.

Source: pravovest-audit.ru/nashi-statii-nalogi-i-buhuchet/12-kriteriya-otbora-nalogoplatelshchikov-dlya-vyezdnoy-proverki/.

If a company meets three or more criteria simultaneously, the probability of an FTA within a 1-2 year horizon is high. A self-check against these parameters takes only a couple of hours.

Stages of a Field Audit and Remaining Maneuvers at Each

This is a critically important section. Most owners think, "I will either win in court or lose." In reality, there are four stages, at each of which various opportunities remain to reduce or eliminate assessments.

Stage 1. Pre-Investigation Analysis

The inspectorate gathers information about the company from open and closed sources. It analyzes tax returns, financial statements, bank movements, counterparties, and VAT chains via ASK NDS-3. This stage is invisible to the taxpayer. It can only be detected indirectly—through document requests as part of pre-investigation measures, summons to the inspectorate for explanations, or inquiries made to counterparties.

What to do at this stage. If there are signs of pre-investigation interest, it is the optimal time to organize document flow, conduct an internal tax audit, and, in some cases, voluntarily file amended tax returns prior to the scheduling of an FTA. Amending a return before an audit is initiated precludes the application of a penalty (Article 122 of the Russian Tax Code is triggered only when a violation is identified by the inspectorate). Pay the assessment and late payment interest—the penalty is waived.

This is the first and most cost-effective maneuver. If the inspectorate has identified a risk area during the pre-investigation analysis, and it can be resolved through a voluntary amendment, the company saves 20-40% in penalties on the assessment amount.

In 2025, 57% of budget revenues from the overall control and analytical work of tax authorities consisted of "voluntary" additional payments by businesses following pre-investigation analysis. That is, prior to court and prior to the audit act. This figure is worth remembering.

Stage 2. The Audit Itself

The decision on an FTA has been issued. The duration is 2 months, with the possibility of extension to 4-6 months. At this stage, the inspectorate: requests documents, conducts witness interrogations, inspects premises, performs signature examinations, and requests information from counterparties and banks.

What to do at this stage. Engage a specialized defense attorney immediately. Not after receiving the act. Before. Every response to a demand, every interrogation protocol, every inspection is evidence that will later be used in the act. The content of responses, the wording in interrogation protocols, the volume of documents provided—all of this forms the material upon which the inspectorate will base its conclusions.

Competent support during the audit at this stage is not about "delaying timelines." It is about forming one's own evidentiary base, which will later form the foundation for objections and the appellate complaint.

A standard mistake by an owner: "I will hire an attorney when the act arrives; why do it now?" By the time the act is issued, half the game has already been played. Interrogations have taken place, documents have been handed over, and the wording in the protocols has been cemented. Reversing this is impossible in 9 out of 10 cases.

Stage 3. Act and Objections

Following the conclusion of the audit, the inspectorate issues an act within two months (10 days for a desk audit). The act is an interim document, not yet a decision. In it, the inspectors record their findings and proposed assessments.

From the moment the act is served, the taxpayer has one month to file objections. This is the first official point for real maneuvers.

What can be done in the objections.

• Refute the inspectorate's conclusions on the merits. Prove the reality of transactions. Submit documents that were not taken into account. Point out calculation errors.

• Submit new evidence. The law does not restrict the right to provide additional documents at the objection stage. It is possible to gather witness testimonies from counterparties, expert appraisals, and specialist opinions.

• Point out procedural violations. Timelines, violations during document requests, violations during witness interrogations. Substantial procedural violations constitute independent grounds for canceling the decision based on the audit results.

• Claim mitigating circumstances. The company's difficult financial situation, lack of intent, a long-standing history of tax compliance. This allows for the penalty to be reduced by at least half (Article 114 of the Russian Tax Code).

• File a motion for the application of tax reconstruction (if grounds exist).

Specialized practice shows that objections can reduce assessments by 30-70% in real cases. Not "eliminate completely"—but realistically reduce them to amounts the company can pay without facing bankruptcy.

Real examples from the public practice of specialized law firms:

• Reduction of inspectorate claims from RUB 27 million to RUB 2 million at the stage of reviewing objections to the act (Etalon Consulting Group, construction firm case).
• Defense against claims exceeding RUB 9.5 million through objections to the FTA act (Etalon Consulting Group, case concerning the reality of transactions with problematic counterparties).

Source: etalon-cons.ru/uslugi/nalogovoe-pravo/osparivanie-resheniya-nalogovoj/.

These are standard figures. Not extraordinary victories—routine practice of a competent defense attorney at the objection stage.

Stage 4. Decision and Appellate Complaint to the UFNS

After reviewing the act and objections, the inspectorate issues a decision on holding (or refusing to hold) the taxpayer liable. This is no longer an interim document, but the final document of the inspectorate.

From the moment the decision is served, the taxpayer has one month to file an appellate complaint with the higher authority—the Regional Tax Office (UFNS). If filed in time, the decision does not enter into force until the complaint is reviewed, and enforcement does not commence.

If the month is missed, the decision enters into force. A standard complaint can be filed within a year, but enforcement is already underway.

As of January 1, 2025, pre-trial appeal became mandatory for all tax disputes, including property-related claims associated with the actions (or inaction) of officials. Without passing through the UFNS, one cannot proceed to court.

The UFNS is the second point for real maneuvers. Here:

• The decision can be canceled in whole or in part.
• It is possible to have the case remanded for a new review by the lower inspectorate.
• Additional evidence not present in the objections can be recorded.
• Recent judicial practice that emerged after the act can be utilized.

A real example is the cancellation of an RUB 11 million tax deficiency assessment through an appellate complaint to the Moscow UFNS (Etalon Consulting Group).

Concurrently with filing the appellate complaint, an application to suspend the execution of the decision can be filed upon the provision of a bank guarantee (as of January 1, 2024, this option is enshrined in the Russian Tax Code). This blocks enforcement until the complaint is reviewed.

And only after passing through the UFNS, if the result is unsatisfactory, does the path to the arbitrazh court open. Where, as seen in the first long-form article of the series, the chances of a complete victory by amount remain at approximately 4.79%.

Therefore, the center of gravity of the defense lies in stages 2 and 3. Not in court. In supporting the audit and in the objections.

Tax Reconstruction: Where It Works in 2024-2026

Tax reconstruction is a mechanism whereby a taxpayer who utilized a scheme involving 'technical' counterparties (shell companies) is assessed taxes not "in full without deductions and expenses," but in the amount they would have paid had they worked directly with a real supplier. This is a critically important distinction.

Without reconstruction: a company purchased goods through an intermediary for RUB 100. The intermediary is a fly-by-night company. The inspectorate denies the VAT deduction and the recognition of expenses. The company is assessed corporate income tax on the full RUB 100 plus VAT on the full RUB 100. The debt is approximately RUB 32 for every hundred in turnover.

With reconstruction: the inspectorate acknowledges that the goods are real, the actual supplier has been identified (e.g., an importer), and the transaction with them is confirmed. The tax is calculated based on the real economics of the operation: deductions and expenses are recognized in the portion corresponding to the real price from the real supplier. Assessments can be reduced significantly.

Key Sources of Legal Regulation

Article 54.1 of the Russian Tax Code. Introduced in 2017. Established the criteria for unjustified tax benefit. Until 2021, the FTS maintained that this article abolished tax reconstruction. That is, if a fly-by-night company was identified, deductions and expenses were denied in full, without calculating real obligations.

FTS Letter No. BV-4-7/3060@ of March 10, 2021. A pivotal document. The FTS recognized the possibility of tax reconstruction—but under strict conditions. The primary condition: the taxpayer must disclose the actual executor of the transaction.

Russian Supreme Court Ruling No. 309-ES20-23981 of May 19, 2021 (JSC Spetskhimprom case). The Supreme Court established: the application of tax reconstruction in transactions with 'technical' companies is determined not by formal, but by material conditions—establishing the real executor of the transaction, including with the assistance of the taxpayer.

Russian Supreme Court Ruling No. 305-ES21-18005 of December 15, 2021. Another important clarification on reconstruction—the position is taken into account by the FTS in current complaint review practice.

FTS Letter No. BV-4-9/12603@ of October 3, 2023 (as amended on January 13, 2025). A review of legal positions based on the results of complaint reviews. Enshrined: Article 54.1 of the Tax Code does not preclude determining the actual size of the tax obligation.

FTS Letter No. KCh-4-9/7026@ of June 21, 2024. A review of positions for Q1 2024. Contains specific reconstruction cases.

When Reconstruction Works in 2024-2026

The FTS and the courts divide taxpayers into two categories.

Category 1. The taxpayer acted intentionally—organized the scheme with 'technical' companies themselves, and knew about the supplier's flaws. They can count on reconstruction only if they themselves disclose the real supplier at the audit stage or in the objections to the act. If the disclosure occurs later (at the UFNS or in court), there will be no reconstruction. This is the Supreme Court's position from the "Firma Mary" case.

Category 2. The taxpayer failed to exercise due diligence—did not know about the supplier's flaws, but could have found out with proper verification. Here, reconstruction is applied under more lenient rules—provided there is a real actual supplier and the transaction genuinely took place.

In both cases, the timing of information disclosure is critical. Disclosed in objections to the act—there is a chance for reconstruction. Disclosed only in court—the train has left the station.

Reconstruction Cases in 2024-2025

• Resolution of the Arbitrazh Court of the Moscow District of July 22, 2024, in case No. A40-107707/2022. Conducting reconstruction for VAT and corporate income tax based on invoices and transport waybills of the real importer-supplier was deemed lawful.

• Resolution of the Arbitrazh Court of the North Caucasus District of March 13, 2025, in case No. A53-39104/2022 (Supreme Court Ruling No. 308-ES24-9169 of June 24, 2024, denied the transfer of the cassation appeal). Reconstruction for transport services involving contracting organizations.

• Resolution of the Arbitrazh Court of the Volga District of July 24, 2024, in case No. A12-4144/2023. Reconstruction for the purchase of fuel and lubricants—the real supplier was established, and the reality of the purchase is not disputed.

Source: buhgalteria.ru/article/obzor-sudebnoy-praktiki-spory-po-nalogovoy-rekonstruktsii.

This is a functioning tool. However, it only works with the correct strategy for disclosure and document preparation. A chaotic attempt to "prove the reality of the supplier" at the court stage without prior disclosure in the objections is almost guaranteed to fail.

Reconstruction in Business Splitting

A separate and highly important case. Section VIII of FTS Letter of March 10, 2021, states: when a business splitting scheme is identified, tax reconstruction is applied. Both the assessed income (consolidated from the group of entities) and the corresponding expenses and VAT deductions are taken into account, as well as taxes paid under special regimes by the consolidated entities.

This means that an assessment for splitting is not "summing up the revenue of all USN companies and paying VAT on the profit," but calculating real obligations taking into account everything that has already been paid within the system. This reduces assessments for splitting by tens of percent in standard cases.

What the Structure of Tax Assessments Reveals

According to FTS data, in 2025, over 80% of all assessments pertained to two taxes:

• VAT — 50.2% of the total assessment amount (RUB 354.7 billion).
• Corporate income tax — 30.4% (RUB 214.8 billion).

Thus, the primary impact of a field audit is always on VAT deductions and corporate income tax expenses claimed through questionable counterparties.

In a single successful field audit in Moscow, the average payment reached RUB 120.68 million (H1 2025). Including penalties and late payment interest, this amounts to RUB 150-180 million. For most mid-sized companies, this sum is close to the value of the entire business.

Source: vedomosti.ru/economics/articles/2026/04/29/1193850-postupleniya-v-byudzhet-ot-viezdnih-nalogovih-proverok-virosli.

What Happens After the Audit: The Corridor from FTA to Subsidiary Liability

This is the most crucial part, which most owners underestimate at the outset.

A field audit is not the final point. It is the beginning of a chain:

FTA → act → decision → demand for payment → inability to pay → bankruptcy → subsidiary liability of the CPD → personal bankruptcy of the director.

Concurrently, along this same chain, the initiation of a criminal case under Article 199 of the Russian Criminal Code (RCC) is possible (if the amount of arrears exceeds the large scale—RUB 18.75 million over three financial years for qualification under Part 1 of Article 199 of the RCC, or RUB 56.25 million for Part 2).

The share of the FTS as an initiator of bankruptcies in 2024 was 24%. This means that every fourth corporate bankruptcy today is initiated by the tax authority specifically following an FTA. A detailed breakdown of this chain is available in my previous long-form article on subsidiary liability.

Real cases from 2024-2025—a tax audit leads to the subsidiary liability of the director:

• Tax assessments of RUB 379 million → bankruptcy → subsidiary liability of the founder and director for the same amount. Resolution of the Arbitrazh Court of the Moscow District of March 11, 2024, in case No. A40-294217/2019.

• Transactions with questionable counterparties in 2018 → assessments in 2020 → subsidiary liability of directors for RUB 122 million in 2025. Resolution of the Arbitrazh Court of the Moscow District of October 8, 2025, in case No. A40-243795/2021.

• FTA → criminal case → bankruptcy → subsidiary liability of the director and chief accountant for RUB 24 million. Resolution of the Arbitrazh Court of the Central District of February 2, 2026, in case No. A23-8727/2019.

Source: pravovest-audit.ru/nashi-statii-nalogi-i-buhuchet/nalogovaya-realnost-v-tsifrakh-i-faktakh/.

This means that defense in an FTA in 2025-2026 is not about "fending off taxes." It is about preventing the emergence of a chain that will subsequently destroy the company and the personal assets of the owner.

What Actually Works: Four Principles of Defense

The same four principles as in the first and second long-form articles of the series. They have been tested by practice across the entire "taxes — bankruptcy — subsidiary liability" chain.

Principle 1. Fully transparent operations. No gray schemes, no 'technical' counterparties (shell companies), no aggressive optimization. Any gray area will be classified as a violation within 2-3 years, and will trigger during an FTA as early as 2025-2026.

Principle 2. Forecasting four years ahead. Tax regulation is moving toward simplification for the state and automation of control. ASK NDS-3, ASK NDFL, the Single Tax Account (ENS), new Supreme Court positions—a new cycle every 2-3 years. Decisions made today must be resilient to rules that will take effect in 4 years.

Principle 3. Strategy of exhausting creditor interest. If an FTA is scheduled and assessments are inevitable—working with time and assets. Delaying through lawful procedural means. Withdrawing assets before the trigger point. Competent management of the personal bankruptcy of the CPD as a way to secure the perimeter. The goal is not to win. The goal is to reach a point where the creditor loses interest.

Principle 4. One hundred percent truth to the client. An attorney who promises to "beat the FTA in court" is hallucinating. Functionally, it is the same as a language model generating convincing text detached from reality. Except the model transparently discloses its nature, while the attorney does not. The true value of a defense attorney lies not in promises, but in navigation: where maneuvers remain, where they are gone, how to limit damage, and how to protect assets in advance.

What Practice Shows: Seven Specific Steps Before and During an FTA

First. Self-check against the 12 FTS criteria every six months. This takes 2-3 hours and costs nothing. If the company is in the red zone for three or more criteria, the probability of an FTA within a 1-2 year horizon is real.

Second. Internal tax audit once a year. It is better to pay more for a specialized expert than less for the in-house accountant who maintains the records. An auditor brings an outside perspective and identifies risk areas that are blurred from the inside.

Third. Terminate relationships with questionable counterparties. Today. Not "when I find a replacement." Today. Connections with 'technical' counterparties are the most frequent trigger for an FTA and the primary source of assessments. Save 5% on the price—pay 100% in assessments plus a 40% penalty plus late payment interest.

Fourth. Organize document flow. All contracts, acts, and primary documents must be in perfect condition. The absence of documents is grounds for a presumption of guilt (Article 61.11 of the Insolvency Law during subsequent subsidiary liability).

Fifth. If a decision on an FTA is received, engage a specialized defense attorney immediately. Not after the act. Not after the decision. Immediately. Every response to a demand, every interrogation protocol forms the inspectorate's evidentiary base. Competent support during the audit accounts for 80% of the future outcome.

Sixth. Do not economize at the stage of objections to the act. Objections filed competently and with an evidentiary base realistically reduce assessments by 30-70%. Objections filed to "brush it off formally" miss the only point for real maneuvers.

Seventh. If the decision is unsatisfactory—an appellate complaint to the UFNS within a month. With a bank guarantee to suspend execution. This blocks enforcement until the complaint is reviewed and provides time.

Frequently Asked Questions (FAQ)

What is the current success rate of field tax audits in Russia?

According to FTS data for 2025, the success rate of field tax audits of organizations is 98%. In Q1 2025 in Moscow, it was 99%. That is, only 1-2% of audits conclude without assessments. The scheduling of an FTA effectively means a guaranteed assessment.

What is the average size of assessments from a field tax audit in 2025?

According to the FTS (Form 2-NK), average assessments from a field audit in 2025 are: RUB 94 million across Russia as a whole, RUB 120.68 million in Moscow (the maximum since 2018), and approximately RUB 130-140 million in St. Petersburg. This is taxes only—excluding late payment interest and penalties.

How long does a field tax audit last?

The standard duration of a field tax audit is 2 months from the date the decision to schedule it is issued. This period can be extended to 4 months, and in exceptional cases, to 6 months. During the suspension of the audit (to request documents from counterparties or conduct expert appraisals), the clock stops.

What to do if a decision on a field tax audit is received?

Immediately engage a specialized defense attorney for tax audits. Not after the act, not after the decision—immediately upon receiving the decision on the FTA. At the audit stage itself, 80% of the future evidentiary base is formed. All responses to demands, interrogation protocols, and submitted documents will later become material for the act.

Is it possible to fend off assessments at the stage of objections to the act?

Yes, and this specific stage is one of two points for real maneuvers (the second being an appeal to the UFNS). Competently prepared objections with an evidentiary base realistically reduce assessments by 30-70% in standard practice. Objections are filed within one month from the moment the act is served.

What is tax reconstruction and where does it work?

This is a mechanism where, upon identifying a scheme with 'technical' counterparties, taxes are recalculated based on the real economics of the transaction—recognizing expenses and deductions in the portion of the real supplier. It is applied based on FTS Letter No. BV-4-7/3060@ of March 10, 2021, and rulings of the Russian Supreme Court. The primary condition: the taxpayer must disclose the real executor of the transaction at the audit stage or in the objections to the act. Disclosure only in court—the train has left the station.

Is pre-trial appeal of an FTA decision mandatory?

Yes. As of January 1, 2025, pre-trial appeal is mandatory for all tax disputes, including property-related claims associated with the actions (or inaction) of tax authority officials. Without passing through the higher tax authority (UFNS), one cannot apply to the arbitrazh court.

What is the penalty for non-payment of taxes following a field audit?

The penalty under Article 122 of the Russian Tax Code is 20% of the unpaid tax amount for negligence and 40% for intent. Additionally, late payment interest is accrued at a rate of 1/300 of the Central Bank key rate for each day of delay (since 2024, increased interest applies from the 31st day of delay). If the violations amount to a large or especially large scale, a criminal case under Article 199 of the RCC is initiated concurrently.

What follows a field tax audit in the worst-case scenario?

The chain: FTA → act → decision → demand for payment → inability to pay → initiation of bankruptcy by the tax authority → inclusion of claims in the register → application for subsidiary liability → personal bankruptcy of the director and owners. Concurrently—a possible criminal case under Article 199 of the RCC. In 2024, the FTS initiated 24% of all corporate bankruptcies—every fourth bankruptcy today begins with an FTA.

Conclusion

A field tax audit in 2025-2026 is a procedure with a 98% success rate. The average assessment grows every quarter. In Moscow—RUB 120 million. In Russia—RUB 94 million. These are not theoretical figures. This is money that is currently being debited from companies' settlement accounts following an FTA.

The goal of defense in this environment is not to "win in court," where the chances of a complete victory by amount are less than 5%. The goal is to limit the size of assessments at the pre-trial stage and prevent the emergence of the "bankruptcy — subsidiary liability — personal bankruptcy" corridor.

Four stages of maneuvers operate for this purpose:

• Pre-investigation analysis: voluntary amendment of tax returns, elimination of the penalty.
• The audit itself: competent support, formation of an evidentiary base.
• Objections to the act: a real point for reducing assessments by 30-70% with the application of tax reconstruction.
• Appeal to the UFNS: the second point for maneuvers, a mandatory stage before court as of January 1, 2025.

Owners who continue to rely on "if anything happens, we will hire an attorney and win in arbitrazh" accelerate their path to subsidiary liability. Those who work preventively and engage a defense attorney at the stage when the audit is scheduled limit the damage to realistic amounts.

We continue to live in the conditions of a post-legal state. Tax law here is one of the most vividly defined layers. Understanding its new logic is a condition for business survival in 2025-2026.

A detailed framework of the transformation of the legal environment is available in the "Algorithm of Complexity" manifesto on fishchuk.su and in the System Synthesis Research Institute project at isslab.ru. The "Kautilya" Telegram channel serves as a laboratory for formulations and current observations.

Here lies a professional diagnosis and real principles of defense. Next comes the work.

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Sources (All Verified as of May 4, 2026)

1. https://pravovest-audit.ru/nashi-statii-nalogi-i-buhuchet/nalogovaya-realnost-v-tsifrakh-i-faktakh/ — Pravovest Audit, FTS statistics 2025-2026
2. https://pravovest-audit.ru/nashi-statii-nalogi-i-buhuchet/12-kriteriya-otbora-nalogoplatelshchikov-dlya-vyezdnoy-proverki/ — 12 FTS criteria
3. https://pravovest-audit.ru/nashi-statii-nalogi-i-buhuchet/podvedeny-itogi-vyezdnykh-nalogovykh-proverok-1-kvartala-2025-goda/ — Q1 2025
4. https://www.vedomosti.ru/economics/articles/2026/04/29/1193850-postupleniya-v-byudzhet-ot-viezdnih-nalogovih-proverok-virosli — Vedomosti, 2025 results
5. https://dolgiplus.ru/blog/biznes-i-finansy/statistika-vyezdnyh-nalogovyh-proverok-kuda-smeschaetsya-fokus-fns — FTA statistics
6. https://www.law.ru/news/43223-tolko-2-vyezdnyh-nalogovyh-proverok-v-2025-godu-okonchilis-bez-donachisleniy-dlya-kompaniy — H1 2025 data
7. https://www.moedelo.org/club/nalogovyj-uchet/statistika-nalogovyh-proverok-za-2025-god — general statistics 2025
8. https://www.klerk.ru/razbory/osobennosti-nalogovogo-kontrolya-v-2025-godu-konspekt-vebinara-s-video/ — Boldinova, webinar summary
9. https://pravo.ru/story/230048/ — tax reconstruction, FTS clarifications
10. https://pravo.ru/story/231911/ — Supreme Court position on reconstruction
11. https://www.advgazeta.ru/novosti/vs-rasshiril-granitsy-nalogovoy-rekonstruktsii — Supreme Court ruling on Spetskhimprom
12. https://www.buhgalteria.ru/article/obzor-sudebnoy-praktiki-spory-po-nalogovoy-rekonstruktsii — reconstruction practice 2024-2025
13. https://www.consultant.ru/document/cons_doc_LAW_459084/ — review of FTS positions on reconstruction 2024
14. https://www.pgplaw.ru/analytics-and-brochures/alerts/pismo-fns-o-praktike-primeneniya-stati-54-1-nk-rf/ — analysis of FTS letter
15. https://pravovest-audit.ru/nashi-statii-nalogi-i-buhuchet/kak-i-zachem-obzhalovat-resheniya-nalogovykh-organov/ — pre-trial appeal
16. https://www.etalon-cons.ru/uslugi/nalogovoe-pravo/osparivanie-resheniya-nalogovoj/ — objection cases
17. https://kontur.ru/articles/2227 — pre-trial appeal procedure

Regulatory Legal Acts:

• FTS Letter No. BV-4-7/3060@ of March 10, 2021
• FTS Letter No. BV-4-9/12603@ of October 3, 2023 (as amended on January 13, 2025)
• Russian Supreme Court Ruling No. 309-ES20-23981 of May 19, 2021 (JSC Spetskhimprom case)
• Russian Supreme Court Ruling No. 305-ES21-18005 of December 15, 2021
• FTS Order No. MM-3-06/333@ of May 30, 2007 (Concept of the FTA Planning System)
• Article 54.1 of the Russian Tax Code
• Articles 100, 101, 138, 139 of the Russian Tax Code (appeal procedure)