Abstract
<jats:p>The article discusses the implementation in Russia of the principle of legal certainty of taxation through tax monitoring. The history of the emergence of such institutions as tax monitoring and motivated opinion in tax legislation is analyzed. Scientific approaches to the implementation of the principle of legal certainty within the framework of participation in tax monitoring, as well as obstacles to the implementation of this principle when challenging a reasoned opinion, are considered. An analysis of the admissibility and limits of expanding the powers of tax authorities in terms of carrying out tax control activities within the framework of tax monitoring was carried out. Based on the results of the analysis of these issues, proposals and recommendations were made to ensure a balance of interests of the state and taxpayers in this area.</jats:p>