In the first half of 2026, Russian courts largely supported the tax authorities in 95.2% of the disputes considered. During the year this figure increased by 13 percentage points. Out of the 2.7 thousand cases where claims of about 170 billion rubles were discussed, about 162 billion rubles were returned to the Federal Tax Service. Experts attribute this dynamic to the worsening of judicial practice and the strengthening of tax supervision. At the same time, an ever smaller part of the disagreements reaches the court: the figure dropped to 17.1%. Thus, the high percentage of victories of the Federal Tax Service was observed simultaneously with a reduction in the number of disputes going to the judicial stage. For companies, this changes the practical assessment of legal protection. Litigation remains an accessible way to challenge claims, but statistics show an extremely high percentage of decisions in favor of the state and a significant portion of the amounts recovered. Against this background, it is especially important how to resolve a tax dispute before going to court.