Annotation

This article analyzes Russian Government Order No. 3523-r of November 29, 2025, "On Approving the National Model of Target Conditions for Doing Business Until 2030" and the Federal Tax Service's Activity Plan for 2026 and the 2027-2031 planning period as the basis for developing legal regulation of pre-trial tax dispute resolution. It assesses the government's planned measures and explores potential solutions for certain aspects, including through amendments to current legislation. The author emphasizes that the modernization of pre-trial tax dispute resolution will not be fully realized without enshrining the concept of a "tax dispute" in tax legislation. Therefore, this article presents this concept for amendments to Article 11 of the Tax Code of the Russian Federation.