On-Site Inspections During Tax Monitoring: New Legal Practice

The FBK Legal team has analysed Case No. А40-71089/25-154-288 brought forward by Inter RAO-Elektrogeneratsiya JSC (hereinafter – the Company) regarding an on-site tax inspection (hereinafter – OTI) during tax monitoring.

Based on its analysis, FBK Legal concludes that participation in the tax monitoring regime does not provide absolute immunity from an OTI. The existence of unfulfilled reasoned opinions issued by the monitoring tax authority may serve as grounds for the Federal Tax Service of Russia to conduct an inspection as a supervisory measure. Consequently, to mitigate the risk of an OTI, taxpayers should actively cooperate with the tax authorities during the monitoring control process and strive to resolve contentious issues, thereby preventing the emergence of unaddressed reasoned opinions.

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