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- Additional advantage: taxes and fines for 16 billion were recalculated for large businesses
Additional advantage: taxes and fines for 16 billion were recalculated for large businesses
Tax audits have become dramatically more expensive for large businesses. In the first half of 2026, the Federal Tax Service spent twice as much as a year ago, and the amount of additional payments almost tripled to 16.3 billion rubles. In Moscow, one such check now results in an average of 220 million claims. Businesses are increasingly refusing to pay immediately: in the Moscow region, the number of complaints has increased by a quarter, although 85% of proceedings end in favor of the tax service. Why the Federal Tax Service is presenting companies with increasingly large bills and whether it is possible to achieve their reduction is in the Izvestia article.
How much money is added by the Federal Tax Service based on the results of inspections
In the first half of 2026, the Federal Tax Service conducted 60 on-site inspections of the largest payers, twice as many as a year earlier, according to the latest data from the service, which was reviewed by Izvestia. As a result, 16.3 billion taxes, penalties and fines were added to the business. This is almost three times more than last year's 5.8 billion.
The Federal Tax Service considers companies with annual revenues of over 35 billion rubles to be the largest taxpayers. These include oil and gas giants and store chains.
Additional charges arise when inspectors find unpaid taxes. The reason may be errors in declarations, underestimation of the income base, illegal business fragmentation or the misuse of benefits and special regimes. In addition to the arrears themselves, companies charge penalties for each day of delay. The fine is usually 20% of the unpaid amount, and if the Federal Tax Service proves intent — 40%.
Most often, businesses dispute claims in the amount of 10 million to 100 million rubles, said Alexey Matyushin, deputy head of the analytical department at the Clean Environment law firm. However, for large enterprises, the bill is increasingly running into hundreds of millions and even billions.
A few years ago, an on-site inspection with an additional 50 million rubles was becoming a regional event. Now, even claims for 500 million are no longer uncommon for large businesses, said Dmitry Lomakin, managing partner of Formula Consent law firm.
In Moscow, the average amount of claims for one on-site inspection increased by almost 60% over the year and reached 220 million in the first quarter of 2026, said Inna Ivanova, head of the "Pre-trial resolution of Tax Disputes" at Lemchik, Krupsky and Partners. Therefore, it is increasingly more profitable for businesses to argue than to immediately agree with the inspection's conclusions, she explained.
In the largest cases, claims exceed 1 billion, Inna Ivanova added. At the same time, not only the complete cancellation of the decision of the Federal Tax Service is considered a success for the company. Even a significant reduction in taxes, penalties and fines allows you to save a good amount.
One of the most high—profile examples is the Zenden shoe holding. Andrey Pavlov, the founder of the network, said that after five on-site inspections, the companies had demands for almost 29 billion rubles. Zenden intends to dispute the claims.
Large sums appear in the court decisions of 2026. Thus, the Moscow Arbitration Court refused to cancel the additional charges of LLC "Flower Row" for 918 million. The inspectorate considered that the company had underestimated taxes using a business fragmentation scheme, it follows from the case file.
In another dispute, the court recognized the legitimate demands of the Federal Tax Service for 407 million to the company that operated the Price gas station network. The tax service found that retail fuel sales were formally transferred to 15 controlled entrepreneurs who applied a simplified taxation system.
There are also smaller, but sensitive claims for companies. Rostov metallotrader Iron is contesting 152 million taxes and a fine. At the request of the company, the court temporarily suspended the inspection's decision, according to the file of arbitration cases. The bankrupt Anapa winery Pervomaisky is trying to cancel additional charges of 45 million rubles, and the total amount of claims against Miratorg-Kursk, which the company disputes, is 102 million rubles.
The Federal Tax Service told Izvestia that they continue to apply a risk-based approach to all taxpayers, including the largest ones.
— The Service informs companies about the identified risks of violating the law before making a decision on the appointment of an on-site tax audit so that they clarify their obligations on a voluntary basis. GNP is assigned to organizations that have refused to do so,— the Federal Tax Service explained.
They also added that the tax service is open to dialogue with businesses.
Why is the amount of additional charges increasing?
Experts attribute the increase in amounts to the development of automatic search for violations and the strengthening of the analytical departments of the Federal Tax Service. Previously, inspectors could detect gaps in the counterparty chain only after a considerable time. Now information systems allow you to find suspicious transactions in almost real time, explained Dmitry Lomakin from Formula Consent.
Therefore, the tax service often comes to a business with a preliminary calculation of possible additional charges and a list of disputed periods. Against this background, the number of requests to lawyers for support of inspections and subsequent proceedings has increased several times, he added.
Alexey Matyushin from Clean Environment confirmed the trend. According to him, even before the start of the inspection, inspectors compile a reasoned list of alleged violations and collect information about the company.
At the same time, the deadlines for inspections are shortened, so the Federal Tax Service may have less time to prepare a convincing evidence base, the expert noted. Businesses are trying to exploit weaknesses in the inspection's reasoning in order to reduce or completely eliminate the requirements.
The number of complaints depends on the region. In some regions, their number has increased by 20-30% or more, said Inna Ivanova from Lemchik, Krupsky and Partners. For example, in the Moscow region, the indicator increased by 25%.
How a business disputes the requirements
The companies' chances of winning remain low. In the Moscow region in 2025, about 78% of tax disputes ended in favor of inspections, and in the first five months of 2026, their share reached 85%, said Natalia Kushnareva, CEO of the NK-Profaudit audit company.
According to her, protection needs to be built during the inspection: to sort out the inspectors' claims, prepare objections, submit documents, calculations and other evidence. After the Federal Tax Service made the decision, and the company unsuccessfully appealed it to the service itself, it is much more difficult to reverse the situation in court, the expert emphasized.
According to Dmitry Lomakin from the Formula of Consent, it is possible to completely challenge the requirements after on-site inspections in less than 5% of cases. Moreover, even a victory in the first instance does not guarantee final success: higher courts may review the decision, he warned.
The proceedings themselves are becoming more complicated, and the materials of some cases take up several volumes, he added. Companies have to hire qualified tax lawyers and lawyers, which requires additional costs. Therefore, experts advise assessing risks in advance and starting protection before the Federal Tax Service makes a decision. Otherwise, the initial arrears, along with penalties and fines, can result in much more serious losses for the business.
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