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The subject of this research is the legislation of the Russian Federation, case law, as well as domestic and foreign doctrine, which allow establishing the essence of legal relations for the purpose of appointment of on-site tax audit. The object of this research is the social relations in terms of appointing an on-site tax audit. The author considers legal aspects associated with the procedural issues of appointing an on-site tax audit, and violations committed by tax officials in appointing an audit. Special attention is given to the problems of qualification of procedural violations as significant, i.e. entailing cancellation of the decision of tax authority, acknowledgement of actions (or inaction) of tax officials as unlawful. The scientific novelty of this work consist in formulation of the criterion of significance of violation of procedural norms of the legislation of the Russian Federation on taxes and fees in terms of appointing an on-site tax audit. Leaning on the results of research of the Russian and foreign doctrine, as well as the analysis of the relevant case law, the author determines the procedural violations of tax officials committed in appointing tax audit, which should result in cancellation of the decisions of tax authorities, an acknowledgement of the actions (or inactions) of tax officials as unlawful. The conclusion is made on the content of the criterion of significance of violation of procedural norms of the legislation of the Russian Federation on taxes and fees in terms of appointing an on-site tax audit.	

nalogi i nalogoobloženie

The concept of significance of violation of procedural norms of legislation of the Russian Federation on taxes and fees in terms of appointing an on-site tax audit