Federal Tax Service Of Russia Research Articles

The relevance of the article is due to the role of tax instruments in ensuring the availability of medical services, in promoting the implementation of innovative technologies in healthcare, and in increasing the attractiveness of the medical business for investors. The article analyzes the current instruments of tax incentives for the development of medical organizations. Based on the data of the Federal Tax Service of Russia, the work assesses the demand and effectiveness of such benefits as a zero rate on income tax for the studied category of taxpayers, as well as exemption from VAT for certain medical services. Based on the results of the study, recommendations are given for additionally structuring tax mechanisms that will enhance the regulatory impact of fiscal payments on the studied area in order to ensure the achievement of state priorities in healthcare.

The state spends large financial resources to support small and mediumsized enterprises, including by providing preferential tax regimes. However, the lack of research on the sector affiliation of taxpayers applying special tax regimes (STR) does not allow assessing the diversification efficiency of certain types of STRs and their prevalence in the regions of the Russian Federation. The article aims to construct the profile of taxpayers applying STRs by industry. Methodologically, the research rests on the theory of taxes and spatial analysis. The methods include comparative and structural analysis, cartographic method. The evidence is statistical tax reporting data of the Federal Tax Service of Russia for 2019–2023. The study reveals that the main beneficiaries of STRs are small and medium-sized enterprises engaged in trade and real estate operations, while the incentives do not work for the knowledge- intensive and manufacturing industries. In most regions where the simplified tax system has been introduced, one type of economic activity solely generates the revenues. For the unified agricultural tax in all regions (except for the Khanty-Mansi autonomous okrug) the maximum share of revenues falls on agriculture; for the professional income tax in all regions the maximum share of revenues falls on natural persons without the specified code of the Russian Classification of Economic Activities. In all regions, the trade, where enterprises apply simplified or patent tax system, dominates in the volume of tax revenues from STRs. The Sakhalin oblast and the Nenets autonomous okrug are the exceptions – the main share of revenues generated by STRs comes from production sharing agreements. The obtained results allow outlining the prospects for the STR development in terms of optimising the composition of beneficiaries, the structure of tax revenues, as well as can be used to design the corresponding regional tax policy.

This article considers the topical issues of due commercial diligence by taxpayers when selecting counterparties. Particular attention is paid to the analysis of judicial practice under Article 54.1 of the Tax Code of the Russian Federation, the problem of “technical companies” and standards for checking counterparties. On the basis of letters and clarifications of the Federal Tax Service of Russia, as well as arbitration cases, key risks are identified and directions for improving due diligence activities are proposed. Conclusions are drawn as to how commercial due diligence affects risk mitigation when choosing a counterparty in order to ensure economic and tax security of business entities.

In the context of rapid digital transformation, tax authorities are increasingly moving away from traditional ob-servation-based control to intelligent predictive analytics systems. The article addresses the current state of digitalization of tax administration in Russia and examines the main initiatives of the Federal Tax Service of Russia. A comparative analysis with foreign countries (USA, UK, Australia, Austria) is presented, as well as a model for predicting the steady growth of income from digital technologies. The novelty of the study lies in the quantitative similar foreign benchmarks for assessing the predicted effectiveness of Russian initiatives in the field of invisible technologies. The results obtained ensure the transition of efficiency to invisible tax control based on data and justify further investments in predictive technologies. Their dynamic development makes it necessary to develop effective ways of measuring their performance in order to achieve long-term fiscal sus-tainability and institutional innovation.

Aim. The work aimed to determine priority fields of digitalization of tax administration in relation to entities of the agricultural sector of the Russian Federation (RF), including an analysis of problems of the current functioning of the unified agricultural tax (UAT) mechanism, and to develop proposals for the implementation of digital solutions aimed at increasing transparency, automating interaction with tax authorities, and reducing the administrative load on agricultural producers.Objectives. The work seeks to analyze the current level of digitalization of tax administration in the agro-industrial complex; to identify organizational, infrastructural and legal barriers to the implementation of digital technologies in the tax policy of the unified agricultural tax; to study the current digital tools used by the Federal Tax Service (FTS of Russia), and assess their applicability to agricultural entities; to develop models of digital administration of the unified agricultural tax taking into account interdepartmental integration and the level of digital maturity of agricultural organizations; to propose a set of measures for the implementation of digital services, mobile applications and training platforms for agricultural workers; to define digital benchmarks for the transformation of tax administration in the industry.Methods. The study employed systemic and comparative legal approaches which enabled to identify structural relationships between tax regulation entities and digital platforms; as well as an economic and statistical analysis of official reporting data from the Federal Tax Service of Russia, the Ministry of Agriculture of Russia, and the Ministry of Digital Development of Russia for 2019–2024 was performed. The project method was used to create a digital administration model for the unified agricultural tax, including a description of the platform functional architecture and an assessment of the expected results. The graphical method is used to visualize the integration links between participants in tax interactions, as well as to compile a comparative table of the current and target state of digital transformation in the industry.Results. It was established that the level of digitalization of tax administration in agriculture remains fragmentary, namely less than 40% of entities use electronic document management; and integration with the information systems of tax authorities is difficult due to the lack of standardized solutions and weak digital infrastructure in a number of regions. Key barriers were identified. These include insufficient digital literacy of taxpayers, low level of Internet access, and poor adaptation of existing digital platforms to the specifics of the unified agricultural tax. A digital administration model was developed, including the creation of a single digital platform for the unified agricultural tax, the implementation of a mobile application, integration with accounting cloud systems, as well as interaction with banks and cadastral authorities. Measures were proposed for the phased implementation of digital solutions with an assessment of their effect by key indicators, namely reporting processing times, the share of digital document flow, and the degree of automation of calculations. The results are systematized in tabular and graphical ways, indicating the promising architecture of tax interaction.Conclusions. The theoretical and regulatory aspects of digitalization of tax administration in the agricultural sector were analyzed with an emphasis on the unified agricultural tax. A need was identified to adapt the system of interaction between tax authorities and agricultural producers to industry specifics, eliminate digital inequality, and optimize information exchange. The scientific novelty consists in the development of a model for the unified agricultural tax digitalization, which includes information exchange, automation of tax calculations, and digital services. Measures for regulation, training, information security, and monitoring with cost assessment were proposed. The results confirmed the model efficiency for successful digitalization of tax administration in the field of agricultural business. The proposed measures can be used in programs for digitalization of tax administration and support of the agro-industrial complex.

Aim. To study the impact of the digital economy on the tax system and identify the main aspects of digital taxation in the modern world in order to understand its features and opportunities for economic development.Methodology. Based on the reporting data of the Federal Tax Service of Russia, statistical data of the Ministry of Digital Development, Communications and Mass Media of Russia and the Bank of Russia, an analysis of the development of the digital economy and its impact on digital taxation was conducted. To write this topic, the author used modern methods of scientific research such as analytical, statistical, methods of grouping, graphical and tabular presentation of data.Results. It shows what digital technologies are used by organizations of the business sector in Russia and other countries. If the state has decided to digitalize any of the spheres of activity, then this process will certainly be associated with high costs, thus the author gives the dynamics of gross domestic costs for the development of the digital economy in Russia. Today, we can no longer exist without digitalization, which improves and makes our lives easier, such as the introduction of the electronic system of fast payments (FPS). But with the development of digitalization, cyber fraudsters have also appeared who stole 15.8 billion rubles from Russian citizens from various banks without their consent in 2023. The author proposes methods for protecting electronic payments in the digital system.Research implications. Digital services are in demand in Russia; they are actively used and developed. Digital services benefit taxpayers by reducing the amount of time spent and requested documents; opportunities for tax and fee evasion. Digital services also have a positive effect on tax authorities – they modernize the tax administration process, thereby reducing the state’s monetary costs. As a result, tax authorities increase the amount of time they spend on solving more complex and ambiguous tasks, transferring routine and monotonous work to digital services. With the introduction of digitalization, tax revenues to the budget system of the Russian Federation have increased, such as, for example, with the introduction of the mobile digital application “My Tax” – an additional 62,517 billion rubles in professional income tax were received by the budget system of the Russian Federation in 2023. The dynamics are shown: the volume of transactions in the fast payment system (FPS); the number of transfers and amounts of purchases made for goods and services by Russian citizens, the number of trade and service enterprises (TSP) accepting payment through the fast payment system.

The article explores the pre-check analysis of taxpayers' activities as a new form of tax control. It has been found that recently, the nature of the implementation of activities within the framework of pre-check analysis by tax authorities has changed significantly, transforming this activity from purely analytical to a control function. The author analyzes the main principles and procedures for conducting pre-check analysis of taxpayers' activities, identifies issues of legal regulation and the procedure for conducting pre-check analysis of taxpayers' activities. It is noted that currently, the procedure and principles for conducting pre-check analysis are regulated by internal documents of the Federal Tax Service of Russia, which are classified as "for official use only," excluding the possibility for taxpayers to become acquainted with these internal documents. At the same time, such a regulatory approach to this form of tax control carries risks of violating the rights and legitimate interests of taxpayers. This research employed general scientific methods (dialectical method of scientific cognition, systemic method, methods of analysis, synthesis, generalization, induction, deduction, observation, explanation, interpretation, and classification, description of concepts and terms) as well as specific legal methods (particularly, the formal-legal method). Based on the conducted analysis of theoretical approaches, positions of scholars and practicing specialists regarding the legal nature of pre-check analysis and the procedure for conducting pre-check analysis of taxpayers' activities, the author concludes that pre-check analysis of taxpayers' activities is a new form of tax control, as it represents a set of measures carried out by tax authorities within the framework of tax control and has legal consequences for the taxpayer. In this regard, it is proposed to include a number of articles in Chapter 14 "Tax Control" of the Tax Code of the Russian Federation that would regulate the procedure for conducting pre-check analysis of taxpayers' activities. To protect the rights and legitimate interests of taxpayers, it is suggested to specify the rights and obligations of tax authorities and taxpayers within the framework of this form of tax control.

The subject of this study is tax risks of agricultural producers associated with business fragmentation. The purpose of the study is to develop proposals for improving taxation and tax control in agriculture, contributing to the reduction of business fragmentation risks. The specific features of taxation in agriculture is conditioned by the mandatory compliance with the share of qualifying revenue from the sale of agricultural products and products of their primary and subsequent processing. This leads to the risk of business fragmentation for dishonest taxpayers. The authors analyze general approaches to identifying business fragmentation schemes and identify the criteria for artificial business fragmentation on the basis of arbitration practice materials and clarifications of the Federal Tax Service. А typical splitting scheme in agriculture is presented and disclosed. It is derived from tax incentives and preferences in agriculture, systematized in tabular form. The existing concept of risk-based approach of tax authorities does not contain special industry criteria. The study proposes a three-element mechanism for preventing splitting risks in agriculture and develops criteria for identifying illegal tax optimization schemes in the industry. The proposed mechanism includes simplification of the procedure for the application of tax incentives; establishment of indicators of “voluntary” use of benefits in agriculture; strengthening of tax control over transactions involving business splitting. The proposals contribute to a more effective implementation of the following classical and modern principles of taxation: fairness, equal competition, plurality of taxation in the sectoral context. The scientific novelty of the research lies in the comprehensive development of a new methodological approach to the formation of a mechanism for preventing the risks of business fragmentation in agriculture, taking into account the current capabilities of tax authorities and sectoral features of the economy. The practical significance of the study lies in the possibility of using the authors’ proposals by the Ministry of Agriculture and the Federal Tax Service of Russia when elaborating measures for the development of agriculture and sectoral tax control.

This article discusses the advantages and features of the use of an automated simplified taxation system (Auto-STS), analyzes the amounts of tax revenue and the number of payers of the new tax regime based on reporting data from the Federal Tax Service of Russia. It is concluded that it is necessary to further improve the new tax regime

Subject. The article addresses the reduction of risks of tax violation. Objectives. The aim is to identify new approaches to leveling threats in taxation with possible use of digital technologies. Methods. The study rests on statistical data from the Federal Tax Service of Russia, employs methods of induction and deduction, and comparative analysis. Results. Existing approaches to reducing tax violations through numerous on-site and costly on-site inspections do not always lead to achieving the objectives. The low level of financial and tax literacy of taxpayers, unconscious attitude to fulfilling taxpayer duties in full require a paradigm shift based on an increase in the number of inspections. To develop the control activities of tax authorities and tax regulation, the "Know the Taxpayer" platform is proposed for ranking individual taxpayers by the level of risk. This will reduce the number of tax offenders. Improving the effectiveness of control due to new opportunities associated with digitalization will speed up tax audits and detection of violations. Conclusions. The proposed measures are aimed at the practical application of new financial security risk management tools by tax authorities through the functionality of information technology.

The emergence of special tax regimes in the Russian tax system is directly related to the development of small and medium-sized enterprises (hereinafter referred to as SME). The birth of a simplified taxation system (hereinafter referred to as STS) can be linked to the adoption of the Federal Law No. 222-FZ which replaced a large number of taxes with a single tax. The introduction of Chapter 26.2 of the Tax Code (hereinafter referred to as TC) of the Russian Federation (hereinafter referred to as RF, Russia) on January 1, 2003 was significant. Despite the measures taken, in terms of small business development indicators, Russia lags far behind developed countries. According to the Federal State Statistics Service (hereinafter referred to as Rosstat), the share of SME in gross domestic product for 2022 was 21%. The share of the “income” object predominates, trade and services continue to be the spheres of activity, the share of SME in regional budget revenues is insignificant. The purpose of the study is to analyse the changes in Chapter 26.2 of the TC of the RF introduced from 2025 by the Federal Law No. 176-FZ, in particular, imposition of the obligation of STS users to pay value added tax (hereinafter referred to as VAT), their impact on the financial position of small business entities, their counterparties, and budget revenues. The study uses methods of analysis, synthesis, comparison, and the tabular one. The work is based on federal laws, official documents of the Government of the RF, Rosstat data, and reports of the Federal Tax Service of Russia on the topic in question. The study has found that introduction of the VAT at a rate of 5 or 7% without the right to deduction into the STS increases the price of goods or products sold by a STS user.

Систематизированы механизмы обеспечения функций подоходного налогообложения. На основе анализа размеров вычетов и ставки НДФЛ с 2021 года по материалам отчетности ФНС России установлена взаимосвязь показателей структуры и динамики налоговых поступлений от НДФЛ в бюджет в разрезе доходов, облагаемых по различным ставкам. Сформулированы направления оптимизации функций подоходного налогообложения с учетом необходимости стремления к бюджетной и социальной эффективности. The mechanisms of ensuring income tax functions are systematized. Based on the analysis of the amount of deductions and the personal income tax rate from 2021, based on the materials of the reporting of the Federal Tax Service of Russia, the relationship between the indicators of the structure and dynamics of tax revenues from personal income tax to the budget in the context of income taxed at various rates has been established. The directions of optimization of income tax functions are formulated, taking into account the need to strive for budgetary and social efficiency.

In the context of countering sanctions from unfriendly countries within the framework of the implementation of the state import substitution program and the food security doctrine, improving measures aimed at developing subjects of the agro-industrial complex is of particular relevance. The purpose of the study is to formulate proposals for improving the mechanism for collecting the Unified Agricultural Tax based on assessing the effectiveness of tax incentives for agricultural producers, using statistical data from the Federal Tax Service of Russia in form No. 5-Unified Agricultural Tax. To achieve this goal, the following tasks were solved: the fiscal and regulatory role of the Unified Agricultural Tax was assessed; tax benefits for agricultural producers were analyzed, including the mechanism for introducing a reduced unified agricultural tax rate in certain regions; The feasibility of applying benefits under the Unified Agricultural Tax was determined using mathematical tools by calculating the pairwise correlation coefficient between the number of registered payers of this tax and the tax payments they paid in the context of federal districts. The methodology used in the study includes the compilation of time series, statistical and correlation analysis of statistical tax reporting data of the Federal Tax Service of Russia in the context of federal districts. Based on the identified scholastic relationship between the number of Unified Agricultural Tax payers and revenues from this tax to the budget system, a conclusion was made about the effectiveness of using this special tax regime in relation to agricultural producers, including regions where preferential rates are applied. The scientific novelty of the research is to increase the efficiency of the provided tax benefits using mathematical tools by analyzing the received tax payments from this category of taxpayers. Efficiency is achieved by reducing shortfalls in budget revenues by narrowing the circle of benefit recipients. Based on a generalization of the results obtained, proposals were made that would allow greater emphasis to be placed on targeting tax preferences to subjects of the agro-industrial complex, manipulating the conditions for their provision, which should strengthen the role of the regulatory function of the Unified Agricultural Tax.

The article investigates the applied aspects of the implementation and development of tax monitoring in the Russian Federation. The research objective is to identify trends, problems, and development prospects of tax monitoring in the Russian Federation based on a comprehensive analysis of institutional transformations and existing statistical data. Special attention is given to assessing its demand among the largest taxpayers based on the dynamics of the number and structure of monitoring participants by industry, the methods of information interaction used, taking into account the organizational features of activities and ownership structure, as well as the number of motivated opinions and the amount of taxes and fees settled by them. The potential impact of the digital transformation of tax monitoring on the state of internal control systems and risk management in organizations, as well as best practices for organizing information interaction and using modern technologies, has been examined. The research was conducted using general scientific methods, economic analysis methods (vertical and horizontal), and statistics (averages, specific indicators). The informational basis of the research consisted of the Tax Code of the Russian Federation and other regulatory acts, reports from the Federal Tax Service of Russia, large companies participating in tax monitoring, and the results of studies on the maturity of internal control and risk management systems conducted by consulting companies. Conclusions were drawn regarding the low proportion of the largest taxpayers who have transitioned to monitoring, as well as its low demand from large private businesses without government involvement. Trends in the development of tax monitoring for 2015–2025 are substantiated: increasing its accessibility; developing a risk-oriented approach by enhancing both the advantages for conscientious taxpayers and the monitoring control functions; and the digitalization of tax monitoring activities for both tax authorities and taxpayers. Problems reducing the demand for monitoring among taxpayers include high complexity and cost of entry; retention of limited effectiveness of motivated opinions; and limited effectiveness of the risk-oriented approach. As a result of studying the projects of tax authorities, prospects for its development have been identified. Elements of scientific novelty include the justified trends and prospects for the development of tax monitoring proposed by the author, as well as suggestions for addressing identified problems. Insufficient attention is paid to the development of joint compliance tools, which is a promising area for research.

The aim of this study is to develop and justify methods for managing project activities in organizations of additional professional education (hereinafter also referred to as DPO) based on advanced artificial intelligence technologies that enable forecasting specific indicators of economic processes and further planning of those. The subject of the research is the organizational relationships arising in the management of project activities within DPO organizations. The analysis of the factors determining the specificity of activities in the DPO segment allowed the authors to develop a project management method and test it using the example of the regional Academy of the Federal Tax Service of Russia. The application of this method will enable DPO organizations to make informed decisions when implementing projects in educational activities aimed at obtaining economic benefits for a specific industry and achieving sustainable growth indicators for such organizations. The scientific novelty of the conducted research lies in the generalization and refinement of the conceptual framework of the studied sphere of activity and the formation of a system of criteria that allows for the assessment of project management effectiveness. In forming the conceptual framework, the criteria determining the effectiveness of project management in DPO organizations were taken into account, such as the presence of managerial competencies among the staff of educational organizations, the alignment of tasks performed by teachers with organizational goals, and the willingness of personnel to participate in projects. The developed management method contributes to the advancement of scientific knowledge regarding the mechanisms of managing project activities in DPO organizations. For the Academy of the Federal Tax Service of Russia, the method consists of simultaneous optimization across all regions of corporate profit tax, personal income tax (PIT), and property taxes based on their corresponding tax base factors, the skill level of employees, and information security in the regions. The optimization is carried out using artificial intelligence technologies including a multi-objective genetic algorithm (MGA), simulated annealing (SA), and pattern search (PS). A conclusion has been made regarding the necessity of implementing new educational programs on corporate profit tax and property taxes, as there is a failure to achieve the projected values for these goals.

Introduction. There is a need to improve the efficiency of tax administration in the dynamically developing digital world. Digital maturity models are an important tool for assessing the state of national tax administration systems and developing appropriate development strategies. The introduction of digital technologies in the tax sphere can significantly improve the interaction between government agencies and taxpayers, improve the quality of tax services and ensure more effective control over tax payments. Goal. To assess the level of digital maturity of the tax administration system of the Russian Federation. Materials and methods. The assessment will be carried out taking into account such factors as the development of tax control and monitoring tools, the availability of technological resources and the complexity of the tasks performed. To achieve this goal, qualitative and quantitative studies were used, including a study of regulatory documents, an analysis of existing digital maturity models and the practice of their application in tax administration. Results and discussion. The results of the study revealed that the Russian tax administration system has completed the digital transformation at the first level. Interaction between tax authorities and taxpayers is now carried out through online platforms and the website of the Federal Tax Service of Russia, which allows for access to up-to-date information and the provision of necessary services. However, the transition to the second level of digital maturity is almost complete only with some reservations, in particular, there is no possibility of analyzing electronic invoices in real time. To achieve full completion of digital transformation, it is necessary to implement advanced information and analytical tools, such as big data technologies, artificial intelligence and blockchain. Conclusion. The Russian tax administration system is confidently moving towards full digital transformation, but to achieve a higher level of maturity, further development of technological capabilities and implementation of advanced solutions are necessary. This will create conditions for more effective interaction with taxpayers and improving the quality of tax services, which will help improve the tax climate in the country.

Introduction. Starting from January 1, 2025, municipalities have the right to impose a tourist tax. For this purpose, a new chapter entitled Tourist Tax has been included in the Tax Code of the Russian Federation. The decision on the introduction of a tourist tax and its amount is made by municipalities. They can also set additional benefits. The mentioned fee is charged for temporary accommodation services. The tax provides for a gradual increase in rates: from 1% of the price of accommodation in 2025, with an addition of 1% per year until 2029 (then no more than 5%). Municipalities can set differentiated rates based on the season and the category of accommodation facilities. At the same time, there is a minimum tax. Such rates can be applied to calendar months that make up tax periods (quarters). Despite the fact that the Federal Tax Service of Russia and the Ministry of Finance have explained the nuances of calculating taxes and using cash registers, in practice, since the tax is new and many taxpayers face its collection for the first time, there are questions that require clarification and in-depth study. Goal. Assessment of the organizational and legal aspects of the introduction of a tourist tax in the Stavropol Territory, analysis of the regulatory framework, administrative and control procedures, identification of possible risks and measures to minimize them. Materials and methods. The study is based on the analysis of open access data, including: the essence and nature of the tourist tax, the history of its application in Russia and foreign experience, the main parameters of the budgets of municipalities of the Stavropol Krai, the legal basis of the tourist tax. Results and discussion. The study found that 508 accommodation facilities with 24,000 rooms have been prepared for tourists in the region for the holiday season. Guests of the region will be able to visit three thousand monuments and more than 300 tourist routes. To maintain and develop all these facilities, huge financial resources are needed, some of which can be provided by the tourist tax. Conclusion. In the course of the study, it was found that the tourist tax is levied on the accommodation facilities, and not on the vacationers themselves. The money goes to the budget of the local administration without a specific purpose, unlike the resort fee, which was sent to the budget of the constituent entity of the Russian Federation, this is a new tax, and some nuances arise when calculating it.

The article explores the new content of the economic content of the principles of convenience and economy in relation to taxation and tax administration in the context of modern digitalization. A theoretical and methodological justification of the criteria for compliance with the principle of convenience and the principle of certainty in relation to tax administration is given. The author proves that in the conditions of modern information systems, the proposed criteria will ensure minimizing the taxpayer’s obligations to provide various types of tax documentation, minimizing the costs of tax administration, maximizing the interaction of tax authorities and taxpayers, as well as avoiding duplication of information. The purpose of this work is to provide a theoretical and methodological justification for the development of tax administration based on the principles of convenience and economy. The objectives of this paper are to analyze the development of the principles of convenience and cost-effectiveness in the context of digitalization; to reveal the new content of the principles of convenience and cost-effectiveness of tax administration; to develop criteria for assessing compliance with the principles of convenience and cost-effectiveness of digital tax administration.. The object of the research is the principles of convenience and cost–effectiveness of tax administration. The main conclusion of this work is that at the current stage of development of tax administration, it is convenient and economical to refuse to file a tax return by a taxpayer and switch to automating tax calculation by the Federal Tax Service of Russia itself through access to all primary documents transferred to EDI operators.

Subject. This article discusses topical issues of tax administration of government tax support instruments. Objectives. The article aims to reveal the main difficulties and trends in tax administration of government tax support instruments. Methods. For the study, I used analysis and synthesis, deduction and induction, analogy, abstraction, as well as description, comparison, and observation. Results. Based on the analysis of judicial practice, the article identifies the areas of control of tax support instruments. It notes that automation due to the technical capabilities of the Federal Tax Service of Russia, the use of agile methodology and the transition from aggregated to partial valuation are promising areas for improving the assessment of the effectiveness of support tools. The formation of a unified register of conditions for the application of tax benefits is proposed as a tool for lawmaking by the authorities. The article also presents risk markers that can be used in the formation of a methodology for determining actual tax liabilities. Conclusions and Relevance. The present-day tax legislation needs to clarify the definition of Tax Benefits, in connection with which it is recommended to use the concepts of Basic and Normative tax structure. In the future, the assessment of the effectiveness of tax instruments based on the automated analytical system Effectiveness of Incentives requires the formation of a methodology and a system of indicators. The results of the study can be used by the Ministry of Finance of Russia to improve the processes of tax administration.

Relevance. A legal entity is a popular legal tool for citizens of the Russian Federation to implement their economic and other interests, as evidenced by the statistical data of the Federal Tax Service of Russia in terms of state registration of legal entities. The scale of interaction between applicants and authorized bodies, as well as persons (organizations) involved in the state registration process, the current (far from optimal) state of legislation on state registration, which creates a favorable basis for the emergence of conflicts and disputes, suggests the need to develop effective forms and means of protecting the rights and legally protected interests of applicants, which, unfortunately, does not exist yet.The purpose of the article is to identify key problems and trends in the development of legislation in terms of appealing (challenging) decisions, actions (inaction) of state bodies (their officials) and other persons (organizations) involved in the process of state registration of a legal entity.Objectives of the study: to analyze the development of legislation in terms of appealing (contesting) decisions, actions (inaction) of state bodies (their officials) and other persons (organizations) involved in the process of state registration of a legal entity; to identify the directions of such development, to understand the reasons for their formation; to identify the main problems and formulate ways to overcome them.Methodology. The article is written on the basis of traditional methods for legal research; the study is based on a systems analysis.Results. It has been established that the existing regulations were formed to a greater extent "spontaneously", in the absence of a special political and legal basis; inconsistency in the provisions of the main regulatory documents has been revealed; problems arising with pre-trial appeal of decisions (actions / inaction) of authorized bodies, actions of the MFC and its employees have been identified; problems with appealing / challenging the actions / inaction of notaries are indicated.Conclusion. The study shows the need for a systemic reform of the rules governing issues of appealing (challenging) decisions, actions (inaction) of state bodies (their officials) and other persons (organizations) involved in the state registration process; directions for appropriate changes are proposed.