"In the first SCEC decided that violation of the deadline for a tax audit is relevant only if it affects the deadline for judicial collection of debts - 2 years. But in this case, the taxpayer must prove that he is not to blame for the long audit (Case No. A21-10479/2019 (https://kad.arbitr.ru/Card/ab986975-98c1-40c1-933d-dbae2fb152f2)).In the case of Euroisol, the economics board confirmed that recalculation in the current tax period is possible only if the old mistakes do not cause damage to the budget (Case No. A72-18565/2019 (https://kad.arbitr.ru/Card/6a23d77a-3232-4c72-a2c7-f7d8ab44e978)). That is, the Federal Tax Service will assess whether you are trying to circumvent the 50% limitation on loss carryforwards and the deadline for the refund of excessively paid tax".

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