There is no point in suing the tax authorities in Chekhov's "The Master Gardener's Tale", the judges acquit the murderer because they don't believe there is a person in the world who is capable of killing everyone's favorite. Grotesque, of course. But if you reverse this plot, you will get an equally absurd picture: and it is much closer to our practice: a court that cannot believe that the tax can be wrong, and therefore condemns everyone. The difference is that Chekhov's judges justified out of love, and ours simply follow the path of least resistance. The data for the first half of 2026 looks like a report on a sports tournament with a known winner: 95.2% of disputes in favor of the tax authorities, a year ago - 82.2%, the previous maximum - 83.4% in 2017. The amount of claims increased by 31%, to 170 billion rubles, of which the tax authorities claimed 162, and the business defended 8 - less than five percent! And it's not because tax officials have become more brilliant. The reason is that the very contention has changed. Previously, in court, the tax authorities had to prove that the company violated the law. Now the company is proving that it was not the camel that did the breaking.

There is no point in suing the tax authorities in Chekhov's "The Master Gardener's Tale", the judges acquit the murderer because they don't believe there is a person in the world who is capable of killing everyone's favorite. Grotesque, of course. But if you reverse this plot, you will get an equally absurd picture: and it is much closer to our practice: a court that cannot believe that the tax can be wrong, and therefore condemns everyone. The difference is that Chekhov's judges justified out of love, and ours simply follow the path of least resistance. The data for the first half of 2026 looks like a report on a sports tournament with a known winner: 95.2% of disputes in favor of the tax authorities, a year ago - 82.2%, the previous maximum - 83.4% in 2017. The amount of claims increased by 31%, to 170 billion rubles, of which the tax authorities claimed 162, and the business defended 8 - less than five percent! And it's not because tax officials have become more brilliant. The reason is that the very contention has changed. Previously, in court, the tax authorities had to prove that the company violated the law. Now the company is proving that it was not the camel that did the breaking.

And it is almost impossible to do it. The Supreme Court limited tax recovery, a mechanism that allowed taxes to be recalculated based on the true economic substance of the transaction, rather than on a formal basis. We worked with technical companies and did not reveal the actual promotions - expenses are not taken into account. all. You lost before the judge even opened the case. Then comes the economy, which, if we're being honest, always operates according to the principles of Darwinism. The state duty to sue government agencies was increased from three thousand rubles to fifty. For a big company it's nothing, but for some it's already money. If you remember that the chance of winning is less than five percent, the claim point disappears altogether. Experts say directly: an appeal is justified mainly in cases of significant amounts. That is, only those who have tens of millions at stake go to court, and very rarely - those for whom the principle is more valuable than money.