On the specifics of determining and implementing criteria for the dishonesty of taxpayers

The article reveals the concept of dishonesty of taxpayers and provides criteria on the basis of which the presence of unlawful intent of the taxpayer in terms of illegal payment of taxes and fees can be justified. The positions of the courts regarding which category of taxpayers should be qualified as unscrupulous are given. The positions of tax authorities used in assessing the dishonesty of tax payers are considered. On the example of judicial practice, the procedure for proving the recognition of a taxpayer as a conscientious executor of the constitutional obligation to transfer taxes and fees to the budget is considered.