The Federal Tax Service defended 95% of the disputed cases in the courts. The amount is a record for the entire period of keeping statistics. Taxpayers managed to keep less than 5% of the disputed amounts, or 8 billion rubles, out of 170 billion rubles considered by the courts in the first half of 2026, RBC reports. In total, the courts discussed 2,700 tax disputes. Their number increased by only 2% compared to the same period last year, while the volume of controversial funds increased by 31%. The disputes won by the tax authorities amounted to approximately 162 billion rubles. (95.2%). This is the maximum for the entire observation period since 2016: neither at the end of the six months nor at the end of the year did the figure rise above 90%. Experts explain the trend by the tightening of judicial practice, stricter control by the Federal Tax Service and the increased cost of a judicial appeal. The effectiveness of the pre-trial settlement is also increasing: before going to court, the taxpayer is obliged to complain about the supervisory decision, the audit report or the actions of the employees to a higher tax authority. The share of cases that reached the court after this procedure dropped from 31.9% in the first half of 2024 to 17.1% in the corresponding period in 2026, according to data from the Federal Tax Service. All the experts are here and at Max.