Codification of judicial tax doctrines in Russia and its influence on tax optimization of companies

The article considers the relationship between the digitalization of tax administration and changes in tax legislation in the fight against abuse of taxpayers their rights. A universal model for assessing the tax risks of an organization is proposed, which can be used in the tax planning of firms. The results of a sample study based on judicial practice that has developed over the past fifteen years during the period of large-scale changes in tax administration and tax legislation are presented, the impact of these changes on the emerging judicial practice and tax optimization of firms is analyzed. The study showed that the digitalization of the tax sphere and the subsequent codification of doctrines of a business purpose and justified tax benefit led to the need to change the paradigm of tax optimization of companies.