Point of law: tax inspection have requested from the taxpayer the documents relating to his contractor, with the reference to Art 93.1 of the Tax Code of Russia. What kind of documents may it request under this article?

Alternative interpretations: 1) it is up to the tax inspection itself to determine which documents are relevant and may be requested from the taxpayer; or 2) tax inspection may request only those documents which relate to the economic activities of the contractor and therefore may contain information on tax offences that the latter could have committed.

Ratio decidendi: the Presidium held that the second interpretation is legally correct. Practical consequences: the Judgment says that prior court decisions in analogous cases if inconsistent with this interpretation may be reversed in the procedure and within the limits envisaged by Art 311 of the Commercial Procedure Code.