Theoretical and legal aspects of legal liability for violations of tax legislation by minor taxpayers

The subject of the research is a complex of theoretical and legal aspects of the legal responsibility of minor taxpayers for violations of the legislation of the Russian Federation on taxes and fees. The focus of the analysis is on the characteristics of the tax-legal status of a minor, the specifics of the emergence and fulfillment of their tax obligation, as well as the mechanism for implementing measures of tax, administrative, and criminal liability in connection with the violations committed. Central attention is given to the problem of the correlation between the legal capacity, capacity to act, and delictual capacity of minors in tax relations, the role and responsibility of their legal representatives in the process of fulfilling tax obligations and holding them accountable. The research aims to identify systemic conflicts and gaps in the current legislation that arise from the lack of a unified approach to defining the age and conditions under which this category of individuals can be held legally responsible. The study utilized methods such as specification, abstraction, analysis, synthesis, and the method of legal comparativism. The scientific novelty of this research lies in the interdisciplinary analysis of the responsibility of minor taxpayers. The legal enforcement mechanism for imposing tax obligations on legal representatives in the absence of legislative regulation has been critically evaluated. Specific proposals for improving the Tax Code of the Russian Federation have been developed. The existing practice has formed a de facto mechanism for imposing responsibility on representatives, compensating for the lack of legal capacity of the minor. However, the absence of legislative consolidation creates legal uncertainty. To address these gaps, it is proposed to: establish in Article 51 of the Tax Code of the Russian Federation the procedure for fulfilling obligations by a representative; differentiate responsibility in Article 107 of the Tax Code for individuals aged 16-18; and establish the responsibility of representatives for violations by minors under 16 years old. This will create a balanced legal regime that takes into account the interests of the state and the rights of minors.