Annotation

This article examines the legal positions of the Constitutional Court of the Russian Federation, as set out in its Resolution No. 1-P of January 15, 2026, regarding the constitutionality of the procedure for calculating personal income tax on the exchange of real estate. It examines the evolution of the approach to taxation of real estate exchange agreements, where tax authorities effectively equated such transactions with two counter-purchase agreements and applied the minimum tax base rule of 70% of the cadastral value of the alienated property.