On the objectives and results of the experiment to establish a special tax regime "Tax on Professional Income" in the context of the Federation Council's recommendation for its early termination

The article is dedicated to analyzing the results of the special tax regime "Tax on Professional Income," introduced by Federal Law No. 422-FZ as a ten-year experiment. The problem under study is related to the Federation Council's recommendation for the early termination of the regime and the need to assess how such an initiative aligns with the goals for which the regime was introduced. The work reveals the evolution of government policy on legalizing unregistered entrepreneurial activity – from attempts to reform the patent system to the creation of a special tax regime. Key issues related to this topic are examined: the principles of legal certainty and the protection of taxpayers' legitimate expectations, the characteristics of the tax experiment, and the issue of substituting labor relations with civil law relations. The research traces the interconnections between the introduction of the tax on professional income, the legalization of entrepreneurial activity, and the assessment of the potential consequences of abolishing the regime for employment and the state's fiscal system. The study utilizes formal-legal, historical-legal, comparative-legal, logical-normative, and systemic methods of analysis, as well as elements of an empirical approach through the use of official statistical data and statements from representatives of government bodies. The scientific novelty lies in justifying that the tax on professional income regime represents not only a tax construction but also an independent form of ultra-small entrepreneurship, the liquidation of which would create significant legal and economic risks. The article demonstrates the contradiction between the proposal for early termination of the experiment and the principles of legal certainty and the protection of legitimate expectations of taxpayers, to whom the legislator initially guaranteed stability of conditions for the entire ten-year term. The author shows that substituting labor relations is a phenomenon known prior to the introduction of the tax regime, and its scale does not correspond to the positive effect of legalizing entrepreneurial activity for millions of citizens. As a significant result, directions for improving regulation are proposed: strengthening control over the substitution of labor relations, developing social insurance mechanisms, and adapting employment legislation and labor law.