Reinsured: the Federal Tax Service took on business violations from many years ago
The tax service began to charge insurance premiums to notaries, lawyers and other private specialists for 2017-2024, follows from the agency's letter (it was studied by Izvestia). We can talk about amounts of about 300 thousand rubles per person, experts say. One of the reasons is that information about the professional status was received by the inspection late. At the same time, the late fees could still be calculated. Some cases have gone to court. Whether there is a chance to cancel the additional charges is in the Izvestia article.
To whom the Federal Tax Service charges insurance premiums for 2017-2024
The tax service took up insurance premiums from many years ago. This year and last year, some private practitioners began receiving notifications about the need to make a payment for the period from 2017 to 2024. This is stated in a letter from the Federal Tax Service (Izvestia has it). The document examines complaints about such claims from lawyers, arbitration managers, notaries, patent attorneys, appraisers, mediators and other specialists. Some of them were charged the amount for eight years at once.
Moreover, penalties for delay could also be accrued for the entire period, said Irina Kuznetsova, head of the audit and consulting company Justicom.
The number of specialists affected by this practice and the total amount of claims were not disclosed in the letter.
Lawyers, notaries and other professionals who work for themselves are required to pay insurance premiums on their own, similar to individual entrepreneurs, Irina Kuznetsova explained.
According to her calculations, the fixed contributions for eight years amount to about 317 thousand rubles per person (if there were no grounds for exemption from payment). Moreover, this is an amount without penalties, the expert added.
For 2026, the total fixed amount of insurance premiums for private practitioners amounted to 57,390 rubles. At the same time, if the income exceeds 300 thousand rubles, you will need to pay another 1% of the excess amount, but no more than 321,818 rubles. Izvestia sent a request to the largest professional associations.
The Moscow Bar Association receives appeals related to disputed insurance premium arrears, said Sergey Zubkov, president of this organization.
The Federal Tax Service told Izvestia that complaints about actions to collect insurance premiums are not widespread and account for a small proportion of the total number of complaints. If the payer believes that the information about him has not been transferred by the authorized body to the tax service, he can independently apply there for registration and settlement of issues, the department added.
Why have the insurance premiums been accrued now?
The obligation to pay insurance premiums arises from the moment of obtaining professional status, said Daniil Sablin, a member of the Russian Bar Association, lawyer and managing partner of the Sabatrust Law Office. However, the tax authority cannot register a person and begin monitoring until it receives the relevant information. If they arrived with a delay, the agency did not know for a long time that the person was obliged to pay dues, the expert explained. It is this time gap that causes demands immediately over such a long period of time.
The absence of charges for several years by itself does not guarantee exemption from the debt on insurance premiums, he stressed.
However, the problem is precisely related to the inconsistency in the exchange of information between the Federal Tax Service and organizations that transmit information about professional status, Irina Kuznetsova from Justicom confirmed. She noted that discrepancies began to appear after the introduction of the Unified Tax Account (ENS).
In the letter, the fiscal department acknowledges cases of late transmission of information. However, the delay does not negate the obligation to account for contributions, it says.
Nevertheless, the fact that specialists are being presented with demands for which the deadlines for compulsory collection have expired, referring to the late receipt of information, is a matter of concern, Sergey Zubkov stressed. According to him, those who are faced with such a problem are provided with methodological assistance: they help to form a legal position, appeal against the decisions of the Federal Tax Service in an administrative manner, and also send representatives to lawsuits.
The main issue in such disputes is when exactly the inspectorate could have found out about the payer's status, said Daniil Sablin from Sabatrust. For example, the information was contained in previously filed 3-personal income tax returns. If the tax service already had such information, it must be taken into account when checking the time of collection.
— The key defense argument is precisely the availability of information from the tax authority on the status of the payer before the official information is received. If the agency has missed the deadline for collection, this information is displayed in the section of the "Overdue debt" section, and then the collection takes place in court," explained Daniil Sablin.
The expert noted that similar situations had occurred in his practice. The inspectorate insists that the deadline should be calculated from the moment the debt is discovered, and the specialist proves that she had the necessary data much earlier. If the court agrees with the payer's arguments, the recovery may be refused.
As the expert emphasized, it is necessary to compare the dates of the obligation, the submission of declarations and the actions of the tax itself.
Courts have already sided with private experts in such disputes. For example, the Arbitration Court of the Ural District supported an arbitration administrator from Bashkiria, to whom the inspectorate presented contributions for 2017-2018. The tax service referred to the lack of information about his professional status. However, the manager had previously submitted 3-personal income tax returns with the appropriate code, so the inspection could determine his status. The court recognized the deadlines for recovery missed and rejected the tax complaint.
However, it is not always possible to dispute the entire debt. In July 2026, the same arbitration court upheld the partial cancellation of the requirement for the governor from the Perm Region for 2019-2021, and the obligations for 2022-2024 remained in force.
The results depend on the circumstances of each case. Apparently, this story will be widespread, Irina Kuznetsova believes.
The payers have the opportunity to protect themselves, Daniil Sablin concluded. The main evidence may be documents that have already been in the inspection. The ability to collect the accumulated debt will depend on what exactly and when the tax service knew about the professional status of the specialist.
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