Constitutional and legal grounds for the practiceof undisputed collection of tax arrears
Disputes between taxpayers and tax authorities on the collection of tax debts are relevant from the very beginning of the entry into force of Part one of the Tax Code of the Russian Federation (hereinafter - the Tax Code of the Russian Federation). However, disputes have not reached so high, i.e. the Constitutional Court of the Russian Federation, before. In 2021, for the first time in its practice, the Constitutional Court considered the question of the constitutionality of applying the general statute of limitations under the Civil Code of the Russian Federation, in disputes about the procedure for collecting tax debts, in cases where the tax authority missed the special deadlines established by the Tax Code of the Russian Federation for applying to court with a claim for collecting tax debts. The Constitutional Court of the Russian Federation confirmed the legality of judicial practice, according to which, in case of missing the deadlines established by the Tax Code of the Russian Federation, the tax authorities retain the possibility of collecting tax.