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New opportunities for business for legal protection in disputes with authorities

A traditionally important component of Russian legal system is array of bylaws issued by regulatory authorities. Many of them de-jure  are not legally binding statutory instruments  but rather recommendations  de-facto applies as legally binding by officials (so-called «interpretation with mandatory effect»).

Most typical examples are bylaw interpretation acts issued by the Russian Tax Office (so-called «pisma» (letters). It used to be hard task to challenge their legal validity due to the former court practice based on statement that de-facto mandatory character of the act was out of court discretion, and at the same time the act couldn’t adversely affect nobody’s  legal rights if de-jure it was not mandatory.