Legal Instruments for Reducing Tax Conflict

Thanks to a streamlined mechanism that describes requirements for taxpayers using a single centralized glossary, the Russian Federal Tax Service has a well-structured data array that suggests there are certain pain points in relations with taxpayers. This helps develop a constructive dialogue to resolve disputes between the tax authorities and taxpayers. The dispute review practice, as well as major work to study and classify appeals from individuals and organizations, shows that not everyone is comfortable with the procedure of a higher tax authority considering complaints. What can we learn from the practice of applying the institution of a reasoned opinion in tax monitoring? What legal guarantees might there be for obtaining a reasoned opinion? As a tool for reducing tax conflicts, should the Russian Tax Code have an agreement between the taxpayer and the tax authority on establishing factual circumstances as an analogue of a settlement agreement in arbitration courts? What alternative procedures for resolving tax disputes can be proposed at the administrative stage to reduce tax conflicts?