Legal Limits on the Use of Artificial Intelligence in the Exercise of Tax Control

The article examines the legal limits of using artificial intelligence technologies in tax control in the Russian Federation. The study looks at how the digital tools used by tax authorities relate to the forms and procedures of tax control established by the Tax Code of the Russian Federation. It is shown that technologies for large-scale data analysis are already incorporated into the activities of tax authorities, particularly in comparing information on taxpayers, identifying tax risks and discrepancies in transactions, including value-added tax control. At the same time, Russian tax legislation does not contain specific provisions defining the legal status of artificial intelligence as a tax control tool, requirements for the explainability of algorithmic results, or a procedure for using such results when making legally significant decisions. The article distinguishes between the analytical and authoritative functions of artificial intelligence. An algorithmic result may be used to select a taxpayer for further control or to formulate a hypothesis concerning a possible violation, but it should not automatically replace evidence obtained through a legally established procedure. The author proposes introducing specific taxpayer safeguards into the Tax Code, including the right to information about algorithmic processing, the opportunity to submit objections, and mandatory verification of legally significant algorithmic conclusions by an authorized tax official.