On the peculiarities of tax disputes in modern conditions

The subject of the research is actual tax disputes in the Russian Federation concerning the application of the criteria of differentiation between legal and illegal tax optimization. New trends in tax disputes have been revealed - the substantiation of the reality of economic transactions by the taxpayer in the presence of «gray» schemes, application of the criteria of «other dependence» of companies for tax control purposes, and the possibility of collecting the organization's tax debt from its head. Conclusions are made about the reasons for the increase in the share of disputes won by the tax authorities, including the increase in the requirements for the formation of the evidentiary base by the tax authorities and the development of the technical potential of the tax service.