Features of changes in tax liability deadlines during the moratorium period

The article examines the issue of changing the deadlines for fulfilling tax obligations under a moratorium. The author focuses on the fact that tax legislation is aimed not only at regulating the procedures for paying taxes and fees, but also at establishing and guaranteeing clear legal forms of procedures that ensure the dynamics of tax relations. This approach is defined as procedural safeguards for taxpayer behaviour at all stages of tax obligation fulfilment, as well as procedural limits on the activities of regulatory authorities in the sphere of control over the behaviour of obligated persons. The author has determined that procedural guarantees for the lawful exercise of powers by regulatory authorities involve the implementation of control in clearly and unambiguously defined forms, one of which is tax audits. The subject of the research in this scientific work is the specifics of desk audits. It is emphasised that the timely submission of tax returns (calculations), the timely registration of tax invoices and/or adjustment calculations to tax invoices in the Unified Register of Tax Invoices, excise invoices and/or adjustment calculations to excise invoices in the Unified Register of Excise Invoices, and the correction of errors in tax invoices are among the main components of assessing the taxpayer’s behaviour during a desk audit. It has been determined that the conduct of a desk audit to assess compliance with registration deadlines primarily concerns the control of value added tax collection. It is emphasised that the set of rights and obligations in the performance of registration actions is individually oriented, since the right to charge tax and draw up tax invoices is granted exclusively to persons who are registered as taxpayers. It has been determined that tax invoices must be registered in accordance with the deadlines specifiedby law. Failure to comply with the deadlines gives rise to grounds for imposing a fine on the taxpayer. The amount of the fine depends on the number of days the deadline has been missed. Undoubtedly, the state has a duty to adapt the legal regulation of relations in the field of taxation in accordance with current realities. The consequences of the pandemic and then the military aggression of the Russian Federation were precisely such circumstances. The author analysed the legally established conditions for suspending deadlines, which were determined by the current legislation on the fulfilment of tax obligations. It was found that the conditions and circumstances of the ‘war’ moratorium overlapped with the conditions of the ‘COVID’ moratorium, and the peculiarities of regulating the relevant relations under these conditions were studied.