Can interregional Inspectorate of the FTS of Russia for major taxpayers to appoint a second site inspection

Interregional Inspectorate of the FTS of Russia for major taxpayers have the right to appoint repeated field tax audit in order to monitor the activities of subordinate tax authorities. Appropriate explanations are contained in the letter of FNS of Russia from April 11, 2019 n SA-4-22/6844@. Namely, we are talking about control over activities on inspections of FNS of Russia for the largest taxpayers that are excluded from the structure of managements FNS of Russia on subjects of the Russian Federation and transferred to the interregional inspection (order FTS of Russia from November 13, 2018 № MMV-7-4/643@ "On the structure and limiting number of territorial bodies of Federal tax service"). Recall that on the basis of paragraph 10 of article 89 of the Tax code, the higher tax authority may conduct re-site inspection in order to control over the activities of subordinate tax body. We add that the decision by results of consideration of materials of tax audit can not be considered invalid if it was issued in violation of the term (letter of Department tax and customs policy of the Ministry of Finance of Russia from January 14, 2019 No. 03-02-08/628).