«What tax risks are fraught with major problems. Top 10 most dangerous» — Valeria Dementyevskaya for RBC
RBC surveyed tax lawyers, asking them to name the main fiscal threats to business in 2026 and rank them. The most popular risks made it into the ranking — the top 10 most dangerous tax threats, according to consultants
The Federal Tax Service has ceased to be an agency that “comes once every three years,” tax consultants state. Today it is a digital machine of continuous monitoring that analyzes transactions in real time, cross-references databases and identifies anomalies before the business has time to explain them. The tax authority no longer catches everyone indiscriminately. It comes where the risk has already been calculated. Field inspections are becoming fewer, but their effectiveness is growing: the FTS is reducing the number of audits while simultaneously increasing the average amount of additional charges per inspection. For business, this means one simple thing: today, additional charges are imposed not for a random error in a declaration, but for a systemic weakness in the model, experts say. RBC surveyed law firms engaged in tax consulting about the highest fiscal risks of 2026 and compiled a top 10 (they are ranked by danger level, with the 10th place being the least dangerous threat and the 1st place being the most dangerous).
10th place. Lack of prudence when selecting counterparties
9th place. Former “gray” schemes: cash, crypto, marketplaces
8th place. Unlawful application of tax benefits
7th place. Saving on payroll and non-payment of personal income tax
Also at risk are individual incomes not related to employment, experts add: “This includes transactions by self-employed persons not covered by the special regime (a common example is commercial real estate leasing), as well as undeclared income from the sale of real estate and vehicles — at the end of the year, the tax authority automatically receives information about changes in ownership and reconciles it with citizens’ declarations,” adds Valeria Dementyevskaya, advisor of the tax practice at Prime Advice Law Offices.
6th place. CFCs, foreign accounts and cross-border payments from Russia
5th place. Intra-group transactions
4th place. Reclassification of payments
3rd place. Substitution of employment relations with civil law contracts
2nd place. Business fragmentation
1st place. “Technical” companies