From the Federal Tax Service to the Prosecutor’s Office: Strengthening Oversight of Corporate Tax Compliance
In 2025, the Russian tax authorities continue to expand the analytical capabilities of their software systems. Businesses are increasingly at risk of being flagged by the Federal Tax Service not only due to transactions involving “paper” VAT or complex chains of counterparties, but also as a result of enhanced pre-audit analytics. Based on such analysis, companies are receiving requests outside the scope of formal tax audits (under Article 93 of the Russian Tax Code ), which are often followed by significant tax reassessments.
Moreover, the enforcement landscape is no longer limited to tax authorities alone. Prosecutors have also begun to scrutinize tax optimization transactions, referring to Article 169 of the Russian Civil Code and Article 57 of the Constitution of the Russian Federation. In Ruling No. 88-КГ23-2-К8 of the Judicial Panel for Civil Cases of the Supreme Court of the Russian Federation dated June 13, 2023, the Court emphasized that transactions resulting in tax underpayment contradict the fundamental principles of law and morality.
If such transactions are found void under Article 169 of the Civil Code, all benefits received under them — including monetary funds, goods, services, or completed work — are to be seized in favor of the state. Relevant court practice is developing in cases such as А79-4318/2023, А72-13241/2024, А65-1815/2025, А65-26184/2024, and А40-176552/2024.
These developments reaffirm the importance of implementing comprehensive counterparty due diligence (KYC), adopting strategic tax planning, and strengthening in-house tax expertise.
Quality Partners and Business Solutions Partners provide end-to-end support to companies in the planning and structuring of transactions, including legal and tax audits. We analyze tax authority requests and prepare substantiated responses in full compliance with applicable law. Our specialists help design legally sound, secure, and tax-efficient business models tailored to our clients’ operational realities.
