Issues of implementing the principle of prohibition of retroactivity in tax law: theory and practice

The article examines the issues of implementing the principle of prohibition of retroactivity in tax law. It discusses the legal nature of this principle, its codification in Russian legislation, and its constitutional foundations. The analysis highlights contradictions arising from the retroactive application of tax norms and judicial practices addressing these issues. Special attention is given to the amendments introduced by Federal Law N 263-FL and their compliance with the principle of legal certainty. The article identifies legal and practical risks associated with retroactive deterioration of taxpayers' positions and proposes legislative measures to address legal uncertainties and protect taxpayers' interests.