Mechanisms of tax optimization: practice of application of the provisions of article 54.1 of the Tax Code of the Russian Federation

The article analyzes the content of article 54.1 of the Tax Code of the Russian Federation, which performs the function of a general anti-evasive rule in the field of taxation. The authors assess the impact of this article on the previously existing law enforcement practice, analyze the contradictions that appeared in the course of its application by the regulatory authorities and the courts. They conclude that the practice of applying Article 54.1 does not lead to the achievement of a balance between private and public interests, and also does not comply with the principle of legal certainty.