Екатерина Уцына

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Нормами налогового законодательства установлено, что в качестве свидетеля налоговыми органами могут быть вызваны лица, которым могут быть известны какие-либо обстоятельства, имеющие значение для проведения налогового контроля (подп. 12 п. 1 ст. 31 Налогового кодекса). В НК РФ разъясняется перечень лиц, которые могут быть вызваны на допрос (ст. 90 НК РФ), но, как поясняет ФНС России, не регламентированы права и обязанности лица, сопровождающего гражданина, вызванного повесткой для допроса в налоговый орган (письмо ФНС России от 17 августа 2020 г. № ЕА-4-15/13203@).
Также законодательством не ограничен и круг лиц, которые могут участвовать или присутствовать при допросе. Помимо этого, при проведении допроса свидетеля должно строго соблюдаться гарантированное право на получение квалифицированной юридической помощи (п. 1 ст. 48 Конституции РФ).
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Как указывает налоговая служба, если при допросе свидетеля он пользуется квалифицированной юридической помощью, то адвокат вправе делать замечания, подлежащие внесению в протокол или приобщению к делу. При этом ответы на вопросы при проведении допроса дает свидетель самостоятельно (п. 3 ст. 99 НК РФ).
При этом стоит учесть, что при проведении налоговых проверок сам адвокат не может допрашиваться налоговыми органами в качестве свидетеля, если он получил информацию, необходимую для проведения налогового контроля, в связи с исполнением своих профессиональных обязанностей и, если такие сведения относятся к профессиональной тайне адвоката.
Что касается участия налогоплательщика или его представителя при проведении допроса свидетеля, то оно НК РФ не предусмотрено (письмо Минфина России от 22 октября 2015 г. № 03-02-07/1/60796).
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Я не могу не отметить стиль и ясность изложения в этой статье. Автор использовал простой и понятный язык, что помогло мне легко усвоить материал. Огромное спасибо за такой доступный подход!
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Статья предлагает объективный обзор темы, предоставляя аргументы и контекст.
Автор предлагает читателю дополнительные материалы для глубокого изучения темы.
Автор старается быть нейтральным, чтобы читатели могли самостоятельно рассмотреть различные аспекты темы.
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Автор предлагает читателю дополнительные ресурсы для глубокого погружения в тему.
Автор представляет сложные темы в понятной и доступной форме для широкой аудитории.
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