Abstract: The article is dedicated to the study of the specifics of tax risks arising in various industries. The authors pay special attention to identifying tax risks and formulating mechanisms for their minimization in the healthcare and military-industrial sectors. An important part of the work is the examination of the relationship between the tax risks of the state and organizations. The research topic aligns with the current direction of Russia's tax policy, as industry-specific tax incentives are a crucial tool for the indirect method of state economic regulation. The author notes that the presence of legislative gaps in tax legislation gives rise to tax risks for organizations and the state itself, while issues that hinder the implementation of tax incentives significantly reduce their effectiveness. The object of the research is the economic relations formed in the process of taxing organizations in various industries. The main research methods used include analysis and synthesis, deduction and induction, analogy and description, structural analysis, dynamic analysis, and tabular and graphical data visualization methods. The scientific novelty of the study lies in the formation of a new approach to identifying business tax risks when applying tax incentives by entities from various industries, which allows for increased targeting of support measures and ensures the effectiveness of tax support in the Russian Federation. The authors identify key industry-specific tax risks and formulate specific mechanisms for their elimination or minimization. It is concluded that there are different scales of tax risks in the healthcare and military-industrial sectors due to various factors, including the degree of interaction with the state and the presence of specific sectoral tax incentives. The practical significance of the research lies in the possibility of using the results of tax risk diagnostics in the practice of calculating tax obligations by organizations, as well as in the process of providing tax consulting services.

Keywords: Tax risks, tax incentives, health care organization, the military-industrial complex, income tax, tax benefits, preferential tax regimes, government regulation, investment tax deduction, tax policy

Abstract: This article is devoted to the analysis of the role of the institute of public control in the prevention of tax offenses and crimes. Tax crimes and offenses, although they do not occupy a leading position in the total number of crimes and offenses committed in the country, pose an exceptional danger to the processes of preservation and development of Russian society and the state, since in the course of their implementation there is a shortage of funds to public budgets of all levels (as well as to the corresponding extra-budgetary funds), or there is a theft of funds from them (for example, by receiving unjustified and illegal tax refunds). The funds stolen and lost during the commission of these crimes and offenses are (as a rule) withdrawn by offenders from the Russian economy (including through withdrawal to foreign bank accounts, purchase of foreign property assets, etc.). The article uses a number of scientific research methods, in particular: formal-logical; comparative-legal; historical and legal. The Institute of Public Control in Russia is aimed at preventing tax offenses and crimes committed, on the one hand, by civil servants of tax authorities (or with their participation), and on the other hand, by taxpayers (payers of other mandatory payments to public budgets and extra-budgetary funds at various levels). The paper formalizes and explores the main problems that prevent subjects of public control from carrying out public control measures aimed at preventing tax offenses and crimes in a full-fledged mode. The article develops and substantiates a system of measures to resolve these problems. The implementation of this system of measures will allow the Institute of public Control in the Russian Federation to act as a key element of the system of prevention of tax offenses and crimes.

Keywords: public control, democracy, Russian Federation, tax offenses, tax crimes, Federal Tax Service, tax inspections, tax audits, field, desk

Abstract: The article discusses the issues of inter-agency interaction between tax and customs authorities. Based on the analysis of the Agreement on Information Interaction between the Federal Customs Service and the Federal Tax Service, as well as scientific literature, levels and main directions of such interaction are identified, and current aspects of cooperation between tax and customs authorities in exercising control and oversight powers are defined. Special attention is paid to the fact that the interaction in question has long historical traditions, and an important characteristic of it is its financial focus. The author highlights a triad of state control ensured by the inter-agency interaction of tax and customs authorities, which includes customs, tax, and currency control. All these types of state control can be included in the structure of public financial control. As a factor confirming the proximity of the oversight functions of the authorities in question, the subordination to the Ministry of Finance of Russia is highlighted. Systemic analysis and synthesis, classification and legal formalization, and the problem method were used in the research. The main conclusions of the conducted study are as follows: 1. It is concluded that contemporary interaction between tax and customs authorities is seen as exclusively informational. 2. In the information exchange and coordination of activities between customs and tax authorities, levels (federal and territorial) and directions (control, regulatory, supportive, informational, and technological) can be distinguished. 3. The control and supervisory competence of tax and customs authorities determines the forms and mechanisms of inter-agency interaction. The basis for all directions of information exchange between departments at all levels is the implementation of tax, customs, and currency control. 4. An important theoretical conclusion is made that the development of issues of interaction between tax and customs authorities is designed to advance the study of various common institutions and mechanisms for these federal executive authorities (for example, the monitoring institution).

Keywords: tax authorities, customs authorities, agreement, interagency interaction, customs control, tax control, currency control, control measure, information interaction, budget

Abstract: The subject of the research is the collisions between the presumptions of public and private law in relation to tax legal relations. The legal nature of the presumption of taxpayer good faith is analyzed, its genesis in constitutional legal doctrine and judicial practice, as well as its correlation with the principles of public legal regulation. Institutional contradictions arising from the simultaneous application of private law and public law presumptions in the field of taxation are identified, including in the context of Article 54.1 of the Tax Code of the Russian Federation. The possibility of applying the principle of estoppel in tax legal relations is considered. An analysis of the judicial practice of the Supreme Court of the Russian Federation and the Constitutional Court of the Russian Federation is conducted from the perspective of forming and developing a legal position on the balance of public and private interests, as well as resolving inter-sectoral conflicts. Dialectical and formal-legal, comparative-legal, and systemic analyses of the judicial practice of arbitration courts and general jurisdiction courts, as well as doctrinal approaches, are carried out. The main conclusion of the research is the establishment of the objective nature of the conflict of presumptions, determined by the inter-sectoral character of tax law. The work formulates an approach to the presumption of taxpayer good faith as a phenomenon of “transnormative reception”: the private law construct is adapted to the public law environment; however, this adaptation is not methodologically flawless, leading to systemic contradictions in law enforcement. Article 54.1 of the Tax Code of the Russian Federation only partially resolved the conflict of presumptions, legislatively enshrining a number of previously formulated judicial positions, but did not create an independent public legal concept of taxpayer behavior standards. A promising direction in doctrine is proposed – the development of a special tax legal theory of presumptions based on the constitutional principles of proportionality, legal certainty, and protection of legitimate expectations. The direct enshrinement in the Tax Code of the Russian Federation of the concept of the “reasonable taxpayer standard” as a public law analogue of the “bona fide participant in civil turnover” standard is suggested, which would eliminate the methodological dependence of tax law on private law constructs and create an independent toolkit for assessing the behavior of subjects of tax legal relations.

Keywords: tax law, public law, private law, presumption of good faith, presumption of innocence, balance of interests, estoppel, tax relationships, doctrine of reasonable expectations, constitutional foundations of taxation