Aggregate liability in the Russian tax law system

Since January 1, 2023, a modern, innovative institute of aggregate liability has appeared in the tax system of the Russian Federation, which includes the following sub-institutions: ENS; ENP; ENS balance; debt. As a result of the adoption of Law № 263-FZ, a restructuring of tax law institutions took place, due to changes in tax legislation, which is a complex and multifaceted process that requires comprehensive scientific analysis and generalization, taking into account various legal factors. The authors are convinced that the expansion of the content of the "tax liability" institute into "aggregate liability" requires a more detailed and comprehensive study by the science of financial law, an updated approach within the framework of the interpretation of current legislation. Discussion and study of the issues under consideration by the science of financial law are important steps towards the creation and development of an effective and fair tax system of the Russian Federation. The study of these issues facing science, together with the norms of Law № 263-FZ, requires scientific rethinking to form new scientific views, concepts in tax law, and the development of practical recommendations for improving tax administration in the Russian Federation.