Protection of the Taxpayer's Legitimate Expectations in the Public-Law Dimension

The doctrine of legitimate expectations in tax law is examined as an institution of public-law nature. Drawing on judicial practice and recent legislative amendments, the study identifies systemic implementation defects: the absence of unified criteria, the insufficiency of compensatory mechanisms, and the inconsistency of judicial interpretations. It proposes statutory enshrinement of the doctrine, unification of law enforcement through a plenary ruling of the Supreme Court of the Russian Federation, and the introduction of preventive procedures. The article substantiates that safeguarding legitimate expectations constitutes a fundamental precondition for the stability of the tax legal order and the trust-based character of tax legal relations.

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Publication Details

Journal
Taxes
Published
2026-10-30
DOI
https://doi.org/10.18572/1999-4796-2026-4-31-35
Primary Topic
Taxation and Legal Issues
Type
article
Field-Weighted Citation Impact
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article

Protection of the Taxpayer's Legitimate Expectations in the Public-Law Dimension

Olga V. Kudryavtseva
2 links
Taxes
Taxation and Legal Issues
article

Protection of the Taxpayer's Legitimate Expectations in the Public-Law Dimension

Olga V. Kudryavtseva
article en

Abstract

The doctrine of legitimate expectations in tax law is examined as an institution of public-law nature. Drawing on judicial practice and recent legislative amendments, the study identifies systemic implementation defects: the absence of unified criteria, the insufficiency of compensatory mechanisms, and the inconsistency of judicial interpretations. It proposes statutory enshrinement of the doctrine, unification of law enforcement through a plenary ruling of the Supreme Court of the Russian Federation, and the introduction of preventive procedures. The article substantiates that safeguarding legitimate expectations constitutes a fundamental precondition for the stability of the tax legal order and the trust-based character of tax legal relations.

Taxes
Peace, justice, and strong institutions
Openalex Percentile: Top 4%
Taxation and Legal Issues
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