Employees of the Federal Tax Service stopped looking for due diligence

In a letter dated December 28, 2017 N ED-4-2 / ​​26807, the Federal Tax Service explained the provisions of Article 54.1 of the Tax Code on unjustified tax benefit.

As indicated by the Federal Tax Service, the concepts reflected in the Resolution of the Plenum N 53, including the concept of “due diligence”, should not be used in the framework of tax audits of taxpayer declarations submitted to the tax authorities after the entry into force of this article, namely August 19^th, 2017.

The FTS also drew attention to the fact that the basis of the lack of due diligence of the taxpayer is not applicable in the framework of field tax audits, decisions on the appointment of which were made after the day this article entered into force.

On materials of the following website: http://www.consultant.ru/cons/cgi/online.cgi?req=doc;base=QUEST;n=174949#05932324776039366