On the issue of some novelties of legislation on liability for tax crimes

The article is devoted to the analysis of basic legislative innovations in the light of the adoption of the key Resolution of the Plenum of the Supreme Court of the Russian Federation dated November 26, 2019 No. 48 "On the practice of applying legislation on liability for tax crimes by courts". We have justified the urgent need for the construction of this document in view of the trend of increasing the number of tax crimes identified by the analysis of statistical data, given the steadily decreasing level of cases of real imprisonment for the analyzed compositions. Despite the fact that the Resolution of the Plenum No. 48 was assessed as very progressive, we identified a number of problematic aspects and inconsistency of the highest judicial instance in presenting its legal positions.