The basic principles of taxation include those that declare certainty, clarity and unambiguity of the legal norm when establishing taxes and fees. Guided by this principle, legislators are obliged to present the texts of tax regulations in simple and understandable language so that tax legal norms are understandable to ordinary taxpayers. In cases where an ambiguous situation is found in the law, the rule that acts in favor of the taxpayer is applied.
The Tax Code of the Russian Federation establishes that for each tax all elements of taxation must be defined, and each taxpayer could clearly understand for himself exactly which taxes and fees, in what order and within what time frame he is obliged to pay. In addition, the amounts of taxes and fees cannot be set arbitrarily; they must be economically justified and applied in such a way that they do not violate the single economic space of the Russian Federation.
World tax practice
In countries that use developed taxation systems, some other legal norms are also enshrined in tax legislation. In particular, many foreign regulations introduce a presumption of innocence for taxpayers or use the fait accompli rule. In addition, the principle of taxation of actually received income, the principle of immutability of tax legislation, awareness of taxpayers and creation of maximum convenience for them may apply.Clause 3 art. 3 Tax Code of the Russian Federationenshrines one of the principles of tax law - the so-called principle of proportionality of taxation. In this material we will try to answer questions that arise when applying this principle in practice.
What are the principles of tax law?
The principles of tax law and the principles of taxation are questions of the theory of the science of tax law. The former are defined as the main initial provisions of this legal branch, its basic ideas, the latter - as the fundamental, basic provisions underlying the tax system of the state.
From a practical point of view, the general principles of taxation refer to the basic guarantees, the establishment of which federal law ensures the implementation and observance of the foundations of the constitutional system, fundamental rights and freedoms of man and citizen, the principles of federalism in the Russian Federation (Resolution of the Constitutional Court of the Russian Federation of March 21, 1997 No. 5-P).
What principles of taxation are enshrined in the Tax Code of the Russian Federation?
The principles of taxation are discussed in Art. 3 Tax Code of the Russian Federation. She calls them the basic principles of legislation on taxes, fees and insurance premiums. They are as follows:
- The principle of legality of taxation (clauses 1 and 5 of Article 3 of the Tax Code of the Russian Federation) means that we pay only those tax payments that are established by the Tax Code. If a payment has signs of a tax, but is not provided for in the code, or if the procedure for establishing it is violated, its collection is illegal.
- The principle of universality and equality of taxation (Clause 2 of Article 3 of the Tax Code of the Russian Federation) comes down to the non-admission of any discrimination, including on social, racial, national, religious and other similar criteria, as well as depending on the form of ownership, citizenship of individuals or place of origin capital.
- The principle of proportionality of taxation (clauses 1 and 3 of Article 3 of the Tax Code of the Russian Federation), first of all, requires taking into account the taxpayer’s ability to pay a tax (fee, contribution), in addition, it establishes the need for an economic basis for tax payments and the inadmissibility of their arbitrary establishment, as well as the prohibition to establish taxes, fees and contributions that prevent citizens from exercising their constitutional rights.
- The principle of the unity of the tax system of the Russian Federation (clause 4 of Article 3 of the Tax Code of the Russian Federation): it is not allowed to establish taxes, fees and contributions that violate the single economic space of our country, in particular, directly or indirectly limiting the free movement of money or goods (work, services) across it ).
- The principle of tax certainty (clauses 6 and 7 of Article 3 of the Tax Code of the Russian Federation): when establishing tax payments, all elements of taxation must be determined. The tax law must be formulated in such a way that everyone knows exactly what taxes (fees, contributions), when and in what order he must pay. At the same time, all irremovable doubts, contradictions and ambiguities must be interpreted in favor of the payer.
What is the essence of the principle of proportionality established in paragraph 3 of Art. 3 of the Tax Code of the Russian Federation?
In theory, the principle of proportionality is divided into 3 subprinciples:
1. Proportionality of taxation: when establishing a tax payment, the actual ability of the taxpayer to pay tax is taken into account.
As a classic example of taking into account the ability to pay tax, one can cite UTII, the size of which is determined taking into account the type of business, and can also be adjusted depending on the operating conditions.
2. Validity of taxation: taxes, fees, contributions must have an economic basis and cannot be arbitrary.
The general idea is that no one tax payment not taken from the ceiling. Each tax is characterized by its own object of taxation, which has a cost, quantity or physical characteristics. The obligation to pay tax arises only if such an object exists.
3. Taxation tolerances: taxes, fees, and contributions that prevent citizens from exercising their constitutional rights are unacceptable.
Taxes are always a certain burden, including some limitation of the constitutionally enshrined right of property. This principle means a ban on excessive taxation and requires proportionality of taxes to the goals of the state. In addition, it should be taken into account when applying measures tax liability. The amount of tax sanctions must correspond to those arising from the Constitution and Art. 3 of the Tax Code of the Russian Federation requirements for fairness and proportionality, differentiation of liability depending on the severity of the act, the size and nature of the damage caused (Resolution of the Presidium of the Supreme Arbitration Court of the Russian Federation dated December 8, 2009 No. 11019/09).
Topic 1. TAX SYSTEM
1. General characteristics tax system of the Russian Federation
2. Concept and types of taxes and fees
3. Principles of tax law
Sources:
· Tax Code of the Russian Federation, part 1
· Resolution of the Plenum of the Supreme Arbitration Court No. 5 of December 28, 2001 “On some issues of application of Part 1 Tax Code RF"
· Information letter of the Presidium of the Supreme Arbitration Court of the Russian Federation No. 71 dated March 17, 2003 “Review of the practice of permitting arbitration courts cases related to the application of certain provisions of Part 1 of the Tax Code of the Russian Federation"
Question 1.The tax system of the Russian Federation is a set of taxes and fees established by tax legislation in the manner and in accordance with the general principles of tax law.
She performs two functions: fiscal and regulatory. The fiscal function is related to the collection cash into the budget system, the main source of budget revenue generation. The regulatory function is divided into stimulating and disstimulating. An effective tax system must ensure a balance between fiscal and regulatory functions.
Structure of the tax system of the Russian Federation
includes:
1) the usual (general) taxation system (Articles 13-15), including federal, regional and local taxes and fees;
2) special tax regimes (Article 18).
Special tax regimes provide for a special procedure for determining the elements of taxation, as well as exemption from the obligation to pay certain taxes and fees provided for by the general (regular) taxation system.
The list of special tax regimes established by the Tax Code of the Russian Federation is closed:
1) unified agricultural tax;
2) simplified taxation system (STS);
3) taxation system in the form of a single tax on imputed income for individual species activities (UTII);
4) taxation system for the implementation of production sharing agreements
According to the order of introduction, these modes are divided:
· voluntary (unified agricultural tax, simplified tax system, tax system for division of production) and forced (UTII);
· federal, regional (STS in terms of the patent system), local (UTII).
Question 2. Concept and types of taxes and fees
The legal definition is contained in Article 8 of the Tax Code. Legal meaning: no one can be obligated to pay taxes, fees, as well as other contributions and payments that have the characteristics of taxes and fees established by the Tax Code, but are not provided for by the Tax Code of the Russian Federation.
Tax payments and parafiscal (other mandatory) public payments.
Other obligatory public payments, as a rule, are of a forced and targeted nature. These include, for example, pollution charges environment(Federal Law “On Environmental Protection” (1991), Federal Law “On Atmospheric Air Protection” (1999), mandatory social insurance premiums(Federal Law of July 24, 2009 “On insurance contributions to the Pension Fund, Social Insurance Fund and Compulsory Medical Insurance Fund”), etc.
A tax is a tax established by legislation on taxes and fees:
A) mandatory individual gratuitous payment;
B) payment in the form of alienation of funds belonging to a person by right of ownership, economic management, operational management
C) payments are made to the budget system of the Russian Federation
Fees are also obligatory payments established by legislation on taxes and fees, but unlike a tax, they are characterized by:
1.) special purpose payment - in connection with the performance of legally significant actions in relation to the payer by state and other authorized bodies (for example, state duty)
2.) special interest – the obligation to pay occurs as a result of the free expression of the taxpayer’s will.
Tax classification and legal meaning of this classification:
A) correctly interpret and apply legislation on taxes and fees;
B) eliminate duplicate payments, double taxation
The criteria (basis of classification) collectively reveal the content and essence of a particular tax.
1. By the authority that imposes taxes: federal, regional and local
2. In order of introduction: compulsory and optional
3. By the level of the budget into which the tax payment is credited: fixed and regulated
4. By subject: organizations, individuals, mixed
5. By object: for income, for consumption, for property, for capital
6. By method of collection: direct (income and property) and indirect. Direct ones are divided into personal and real. Indirect – individual and universal.
7. According to the frequency of collection: regular and one-time (previously inheritance and gift tax, unreasonably abolished)
8. By target orientation: abstract and targeted
9. According to the principle of tax jurisdiction of the state: resident and territorial.
Question 3. Principles of tax law (Article 3 of the Tax Code of the Russian Federation)
Legal significance: 1) the basis of law enforcement activities 2) taxes and fees must be established in accordance with the principles of tax law provided for by federal legislation.
Industry principles of tax law are directly enshrined in specific regulations tax laws(norms-principles) are derived from the meaning of these norms. It's about about textual and semantic forms of expression of legal principles. These, in our opinion, include the following:
1. The principle of universality and equality of taxation and the prohibition of discrimination in tax legal relations. Taxes and fees cannot be discriminatory and applied differently based on social, racial, national, religious and other similar criteria.
2. The principle of fair, proportionate taxation means 1) each tax must have an economic basis (property, income, etc.); 2) the tax cannot be arbitrary, it must take into account the actual solvency of the taxpayer
3.The principle of unity of the tax system, i.e. taxes and fees should not violate the unity of the economic space of the Russian Federation, restrict the free movement of goods and financial resources within the Russian Federation, or otherwise limit the economic activities of taxpayers.
4. The principle of prohibition of establishing taxes and fees that prevent citizens from exercising their constitutional rights.
5. The principle of certainty of tax liability. When establishing taxes, all elements of taxation must be determined (Article 17 of the Tax Code). Acts of legislation on taxes and fees must be formulated in such a way that everyone knows exactly what taxes (fees), when and in what order he must pay.
6. The principle of one-time taxation. This principle has only semantic consolidation (Article 38 of the Tax Code) and means a prohibition of taxation of the same object for the same tax period tax of one type (type).
7. The principle of self-payment of tax. This principle also has only semantic consolidation; its continuation is the catchphrase “taxes are not negotiated” (the prohibition of “tax clauses” in contracts).
Article 3. Basic principles of legislation on taxes and fees
1. Every person must pay legally established taxes and fees. Legislation on taxes and fees is based on the recognition of the universality and equality of taxation. When establishing taxes, the actual ability of the taxpayer to pay the tax is taken into account.
2. Taxes and fees cannot be discriminatory and applied differently based on social, racial, national, religious and other similar criteria.
It is not allowed to establish differentiated rates of taxes and fees, tax benefits depending on the form of ownership, citizenship of individuals or place of origin of capital.
The paragraph is no longer valid.
3. Taxes and fees must have an economic basis and cannot be arbitrary. Taxes and fees that prevent citizens from exercising their constitutional rights are unacceptable.
4. It is not allowed to establish taxes and fees that violate the common economic space Russian Federation and, in particular, directly or indirectly restricting the free movement of goods (work, services) or financial assets within the territory of the Russian Federation, or otherwise limiting or creating obstacles to the economic activities of individuals and organizations not prohibited by law.
5. The paragraph is no longer valid.
The paragraph is no longer valid.
No one can be obligated to pay taxes and fees, as well as other contributions and payments that have the characteristics of taxes or fees established by this Code, are not provided for by this Code or are established in a manner other than that determined by this Code.
6. When establishing taxes, all elements of taxation must be determined. Acts of legislation on taxes and fees must be formulated in such a way that everyone knows exactly what taxes (fees, insurance premiums), when and in what order he must pay.
7. All irremovable doubts, contradictions and ambiguities in acts of legislation on taxes and fees are interpreted in favor of the taxpayer (fee payer, insurance premium payer, tax agent).
The origins of the formation of universal principles of taxation were the classics economic science. It is enough to cite the names of such outstanding scientists as A. Smith, D. Ricardo, V. Petty, A. Wagner and others, whose fundamental works laid the foundation for modern taxation. In particular, A. Smith, in his work “An Inquiry into the Nature and Causes of the Wealth of Nations” (1776), first substantiated a number of principles of taxation that are still relevant today. He referred to them principle of justice, which consists in the universality and proportionality of taxation; certainty principle, which in modern interpretation means that the tax must be established in such a way that each taxpayer knows exactly what taxes, when and in what amount he must pay; principle of convenience, whereby every tax shall be collected at such time and in such manner as is most convenient to the taxpayer; efficiency principle, according to which the administrative costs of collecting taxes should not be greater than the tax revenues themselves.
Principle of taxation– fundamental, basic provision underlying the tax system of the state. Some of these principles are established normatively, others are derived through the interpretation of tax legislation by a court or scientific doctrine. Some principles are industry-wide or cross-industry in nature, others regulate legal institutions, sub-institutions, or even individual aspects of taxation. Thus, the principles of tax liability as an independent institution of tax law are enshrined in Chapter 15 of the Tax Code of the Russian Federation and include the requirement of legality, the presumption of innocence, one-time and individualization of punishment, the principle of adding tax sanctions, etc. Article 40 of the Tax Code of the Russian Federation establishes special principles determining the price of goods (works, services) for tax purposes.
General principles taxation are enshrined in Art. 3 of the Tax Code of the Russian Federation “Basic principles of legislation on taxes and fees”:
1. . Every person must pay legally established taxes and fees. Legislation on taxes and fees is based on the recognition of the universality and equality of taxation. When establishing taxes, the actual ability of the taxpayer to pay the tax is taken into account.
2. . Taxes and fees cannot be discriminatory and be applied differently based on social, racial, national, religious and other similar criteria. It is not allowed to establish differentiated rates of taxes and fees, tax benefits depending on the form of ownership, citizenship of individuals or place of origin of capital.
3. . Taxes and fees must have an economic basis and cannot be arbitrary. Taxes and fees that prevent citizens from exercising their constitutional rights are unacceptable.
4. . It is not allowed to establish taxes and fees that violate the single economic space of the Russian Federation and, in particular, directly or indirectly restricting the free movement of goods (work, services) or financial assets within the territory of the Russian Federation, or otherwise limiting or creating obstacles to the economic activities of individuals and organizations not prohibited by law.
5. . When establishing taxes, all elements of taxation must be determined. Acts of legislation on taxes and fees must be formulated in such a way that everyone knows exactly what taxes (fees), when and in what order he must pay. All irremovable doubts, contradictions and ambiguities in acts of legislation on taxes and fees are interpreted in favor of the taxpayer (payer of fees).
Let's consider these principles in more detail.
Principle of legality of taxation.
Legality is a multifaceted legal category, which in the literature refers to legal principle, sign of law, method public administration, special regime of social life, result legal regulation etc. Summarizing the positions expressed in the literature, we can determine legality How accurate and constant compliance by all subjects of law with regulatory requirements.
The legal institution of legality includes two components. The first concerns the sphere of lawmaking, where legality consists in the legislator’s compliance with certain basic ideas, provisions, principles, requirements for the preparation, adoption, and implementation of normative legal acts. Violation of these requirements in form or in essence entails damage normative act, makes it contestable, allows participants in legal relations to demand its cancellation. The second component of legality covers the sphere of implementation (application) of law and is expressed in the strict implementation of legal norms by all participants in legal relations, including the state. In the field of taxation, both components are present.
Analysis of tax legislation, doctrinal sources and judicial practice allows us to formulate the basic requirements for legally established tax payments:
· taxes are established by representative bodies of state power and local self-government;
· taxes are established in the form of acts of tax legislation in compliance with the law-making procedure;
· acts of tax legislation must be of a legal nature;
· when establishing a tax, the principle of certainty of taxation must be observed, in particular, all its elements that are necessary and sufficient to calculate and pay the tax must be clearly and clearly defined;
· tax legislation must be properly implemented.
Expanding the concept of “legally established taxes and fees”, Constitutional Court The Russian Federation has repeatedly indicated that a tax or fee can only be established by law; taxes levied not on the basis of law cannot be considered legally established.
The principle of universality and equality of taxation.
According to Art. 57 of the Constitution of the Russian Federation, everyone is obliged to pay legally established taxes and fees. The universality of taxation lies in the fact that every member of society is obliged, to the extent possible, to participate in the creation of centralized financial funds of a public nature.
Note that the Tax Code of the Russian Federation expands the content of this principle by subject, establishing that “ every face must pay legally established taxes and fees.” While Art. 57 of the Constitution of the Russian Federation, located in Chapter 2 “Rights and freedoms of man and citizen”, enshrines tax liability regarding only individuals The Tax Code of the Russian Federation extends the requirement of universal taxation and on organizations. The Constitutional Court of the Russian Federation indicated that “tax – this is an unconditional, attributable condition for the existence of the state, therefore the obligation to pay taxes, enshrined in Art. 57 of the Constitution of the Russian Federation, applies to all taxpayers as an unconditional requirement of the state.” At the same time every face(both citizen and organization) is obliged to pay legally established taxes and fees in respect of which it is recognized as a taxpayer.
The principle of tax equality means, first of all, the prohibition of any discrimination in the tax sphere. We are talking about the formal legal equality of taxpayers before the law and the court, about equality of their tax and legal status. Tax Equality – a particular manifestation of the universal, general legal principle of formal legal equality, operating in all branches of modern law. In its most general form, this principle is enshrined in Art. 2 of the Universal Declaration of Human Rights: “Everyone is entitled to all the rights and freedoms set forth in this Declaration, without distinction of any kind, such as race, colour, sex, language, religion, political or other opinion.” , national or social origin, property, class or other status.” Article 19 of the Constitution of the Russian Federation proclaims: “Everyone is equal before the law and the court. Any form of restriction of the rights of citizens on the basis of social, racial, national, linguistic or religious affiliation is prohibited.”
The principle of equal tax burden does not allow the establishment of discriminatory tax rules depending on both the organizational and legal form and the nature (content) of the entrepreneurial activity of taxpayers. In particular, the Constitutional Court of the Russian Federation indicated that differentiation of tax payment regimes cannot be established for non-economic reasons, including based on social differences and other similar criteria, since this contradicts the constitutional principle of equality.
The principle of proportionality of taxation.
Proportionality of taxation includes the requirements:
· proportionality: when establishing taxes, the actual ability of the taxpayer to pay the tax is taken into account;
· justification: taxes and fees must have an economic basis and cannot be arbitrary;
· admissibility: taxes and fees that prevent citizens from exercising their constitutional rights are unacceptable.
The requirement of proportionality logically complements the principle of universality of taxation: everyone participates in the formation of centralized budgetary and extra-budgetary funds in proportion to your actual ability to pay taxes. Thus, a differentiated approach to taxation objects of different sizes is assumed. By general rule, the more tax base(size land plot, property value, engine power, amount of income or profit), the more tax the taxpayer must pay.
The establishment of taxes and fees must be economically justified and expedient, based on comprehensive expert and statistical analysis financial situation in the country, be linked to the budget process, and comply with the declared political goals of the state. At the same time, the total amount of budget expenditures (the state’s needs for budget funds) cannot act as a determining criterion in taxation. The budget deficit itself, that is, the lack of financial resources from the state, does not yet constitute a necessary and sufficient “economic basis” for levying taxes and fees, although it certainly affects the structure of the tax system.
Since taxation always means certain restrictions on property rights - one of the fundamental rights and freedoms of a person, the legislation on taxes and fees is fully covered by the provisions of part three of Art. 55 of the Constitution of the Russian Federation that the rights and freedoms of man and citizen can be limited by federal law only to the extent that this corresponds to certain constitutionally significant goals, that is, in proportion, commensurate with them.
Taxation that paralyzes citizens' exercise of their constitutional rights must be recognized as disproportionate. The tax should not be overly burdensome (and even more so, ruinous), should not kill interest in socially useful activities, and also should not push the payer into the “shadow” sectors of society. In the field of taxation, the principle of proportionality dictates that the legislator prohibits establishing regulation in such a way as to provoke law-abiding citizens to conceal their income and understate the tax base.
The principle of unity of the Russian tax system.
The requirement for the unity of the tax system of the Russian Federation logically follows from the constitutional and legal principles of a single financial policy and the unity of the economic space of Russia. According to Art. 8 of the Constitution of the Russian Federation in the Russian Federation guarantees the unity of the economic space, the free movement of goods, services and financial resources, support for competition, and freedom of economic activity. Article 74 of the Constitution of the Russian Federation establishes: “On the territory of the Russian Federation, the establishment of customs borders, duties, fees and any other obstacles to the free movement of goods, services and financial resources is not allowed, and restrictions on the movement of goods and services may be introduced in accordance with federal law, if this is necessary to ensure safety, protect human life and health, protect nature and cultural values.”
Currently, the Russian tax system is relatively centralized nature. The establishment of general principles of taxation and fees, the formation of a tax system, including, inter alia, an exhaustive list of regional and local taxes and fees as sources of revenue to the budgets of constituent entities of the Russian Federation and local budgets, is carried out by federal law in accordance with the Constitution of the Russian Federation.
A comprehensive list of taxes and fees at all levels is enshrined in the Tax Code of the Russian Federation. “Based on the need to achieve a balance between the rights of constituent entities of the Russian Federation to establish taxes and fees, – indicated by the Constitutional Court of the Russian Federation, – priority of fundamental human rights and freedoms and the unity of the economic space of Russia tax policy strives to unify tax exemptions. Serves this purpose exhaustive by its nature, a list of regional taxes that can be established by government bodies of constituent entities of the Russian Federation, and the resulting restrictions on the introduction of additional taxes and mandatory contributions, as well as on increasing tax rates and tax payments.” In accordance with paragraph 6 of Art. 12 of the Tax Code of the Russian Federation cannot establish federal, regional or local taxes and (or) fees not provided for by the Tax Code of the Russian Federation. Federal, regional and local taxes and fees are also abolished by the federal legislator.
The unity of the economic space and, consequently, the unity of the tax system is ensured by a unified system of federal tax authorities. At the same time, tax authorities, being classified as federal economic services, in accordance with the Constitution of the Russian Federation, are under the jurisdiction of the Russian Federation; tax authorities in the constituent entities of the Russian Federation are territorial bodies of federal executive authorities, and not bodies of the constituent entities of the Russian Federation.
Principle of tax certainty.
The requirement for certainty is the most important feature of law as a system of social norms. Sources of law, especially legislation, are distinguished by a special legal language and a special legal technique. We are talking, first of all, about clarity, clarity, unambiguity of presentation normative material. The law must accurately record the requirements for people’s behavior, the scope of possible, proper and prohibited behavior, describe in detail possible or required options for lawful actions, and the consequences of violating them.
The language of tax legislation should be publicly available for perception, understandable to everyone, designed not for a narrow specialist, but for an ordinary, “average” Russian. Particular importance is attached here to the rule formulated by ancient Roman jurists: Leges intellegi ab omnibus debent - laws must be understandable to everyone.
Issues of certainty of tax rules have been repeatedly raised in judicial practice The Constitutional Court of the Russian Federation, which made the most important conclusions that in the Russian Federation, as a rule-of-law state, tax laws must contain clear and understandable norms. This is precisely the reason for the prescription of the Tax Code of the Russian Federation that the necessary elements of taxation ( tax obligations) must be formulated in such a way that everyone knows exactly what taxes and fees, when and in what order they are obliged to pay. The formal certainty of tax rules should ensure their correct understanding and application. The vagueness of the tax norm, on the contrary, can lead to its arbitrary and discriminatory application, which is not consistent with the principle of the rule of law. government agencies and officials in their relations with taxpayers and thereby - to a violation of the principle of legal equality and the resulting requirement for equality of taxation. Therefore, the tax provided for in defective - from the point of view of the requirements of legal technology - norms cannot be considered legally established (Resolutions of the Constitutional Court of the Russian Federation of March 28, 2000 No. 5-P, dated February 20, 2001 No. 3-P, etc.).
According to paragraph 7 of Art. 3 of the Tax Code of the Russian Federation, all irremovable doubts, contradictions and ambiguities in acts of legislation on taxes and fees are interpreted in favor of the taxpayer, payer of fees. Unfortunately, the terms “doubt”, “contradiction”, “ambiguity” are not defined normatively and are of an evaluative nature. At the same time, when considering tax disputes based on different interpretations by tax authorities and taxpayers of the norms of legislation on taxes and fees, courts need to assess the certainty of the relevant norm.
Security questions:
1. Define tax law. List its main sources.
2. Describe the principles of tax legislation.
3. What is meant by tax legislation?
4. What groups are the sources of tax law divided into?
5. Do they have legislative acts about taxes and fees retroactive?
6. Define the relations regulated by the legislation on taxes and fees.
7. List the methods of tax law.
8. Describe the principles of tax legislation.
9. Expand the content of the principle of proportionality of taxation.
10. What is meant by the principle of unity of the Russian tax system?
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