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Constitutional Court of Russia recognized the lawfulness of seizure of documents from the counterparty

... the fact of the offense. Employees of the tax authority during the seizure are obliged to report in respect of whom and for what offense the audit is being carried out, as well as for what reason the documents are being sought here. Thus, the seizure resolution itself must contain information that reflects both the subject of the audit and the rationale for searching for the necessary documentation. What is more, the counterparty has the same rights as the person being audited.

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