Annotation

The article examines a proposal for a risk insurance mechanism related to the unjustified enforcement of collection actions by the Federal Tax Service (hereinafter referred to as the FTS) against a taxpayer’s funds in the IT sector. The insurance event will be considered to be the FTS’s cancellation of the decision to enforce collection against the taxpayer’s funds in accounts, followed by the cancellation of this decision in court or out of court, as well as the failure to return erroneously collected funds and the delay in doing so under Article 46 of the Tax Code of the Russian Federation (TC RF).