УЧАСТНИКИ НАЛОГОВЫХ ПРАВООТНОШЕНИЙ

Abstract

The paper considers the reduction in the composition of subjects of tax legal relations because of amendments to Art. 9 of the RF Tax Code. The authors analyze possible consequences caused by the quantity changes in the composition of members of tax legal relations in the taxes and fees legislation and what impact it had on tax legal relations. The paper considers the participants of tax legal relations and the peculiarities of their status. In particular, the paper examines in more detail such subjects as taxpayers, payers of fees, tax agents, largest taxpayers, and a consolidated group of taxpayers. Using the statistical data, the authors analyze the activity dynamics and the change in the number of certain categories of taxpayers and classify members of tax legal relations. According to the given classification, the authors analyze the legal status of the participants in tax legal relations defined in the Tax Code of the Russian Federation. Individually, such tax relations participant as a private entrepreneur is considered. The authors present the reasons for dynamic changes in the quantity composition of individual entrepreneurs from 2018 to early 2021. The paper assesses the absence in the RF Tax Code of such entities as the RF Ministry of Finance (financial authorities), credit organizations (banks), procedural persons (experts, specialists, witnesses, attesting witnesses), considers their functions and responsibilities. Based on the study results, the authors reasonably conclude that despite their absence in tax legislation as subjects of tax relations, they have not ceased to be actual participants in tax relations. Reasoning from this fact, the authors propose amending the RF Tax Code and including them in the list of subjects of tax legal relations, as well as introducing legal certainty and defining their legal status.