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- System unit: The Federal Tax Service began to massively freeze business assets during inspections
System unit: The Federal Tax Service began to massively freeze business assets during inspections
The Federal Tax Service has begun to collect debts from businesses more harshly: companies are increasingly not only blocking accounts, but also actually freezing property — they are prohibited from selling, mortgaging or re-registering assets without the consent of the inspectorate. Moreover, not only money, real estate, and cars are now subject to restrictions, but also trademarks, patents, software, and even brand rights. As lawyers told Izvestia, if earlier such measures were applied pointwise, now they are applied in about 85% of disputed cases. What new control tools the tax service has received and who is at risk can be found in the Izvestia article.
Why does the tax service freeze assets?
If a company owes taxes, the Federal Tax Service may, after verification, take interim measures — freeze some of its assets and restrict operations on accounts. This usually happens if the inspectorate fears that the business will withdraw the property and then it will be difficult to collect the debt.
Moreover, not only real estate, cars, or money can now be subject to restrictions, but also intangible assets, such as trademarks, software, patents, databases, and even claims against counterparties. This is stated in the letter from the Federal Tax Service (Izvestia has studied it), and the approach itself has been in effect since 2026, said Evgenia Sabitova, a member of the Union of Blogging Lawyers.
According to her, this does not mean that the tax service will "take away" the brand or software. However, the company may lose the opportunity to sell, mortgage or re-register such assets without the consent of the inspectorate.
This is a painful scenario for many modern companies, said Alexander Khaminsky, head of the Law Enforcement Center in Moscow and the Moscow Region. Nowadays, businesses often have a minimum of real estate and equipment, and the main value is concentrated in intellectual property. Therefore, the Federal Tax Service is increasingly using interim measures specifically against intangible assets, he stressed.
Due to such restrictions, businesses may lose the ability to manage patents, trademarks and accounts receivable, explained tax consultant Alla Milyutina.
Formally, the company continues to own assets, but it becomes much more difficult to use them for transactions or to attract financing. For example, a company will not be able to sell a brand, transfer the rights to software, or issue a license without the consent of the tax service.
For ordinary trading, this is unpleasant, but not fatal. But for an IT business or a content producer, such measures can become critical, because in many cases it is intellectual property that is the main asset of such companies, Evgenia Sabitova noted. This increases the risks for partners and investors, and in some cases may even lead to bankruptcy.
The tax service itself is now applying security measures much more often. If earlier it was more of a point tool, now restrictions are introduced in about 85% of disputed cases after inspections, said Alla Milutina.
The Federal Tax Service has indeed tightened its control, BGP Litigation lawyer Roman Umerov confirmed. According to him, interim measures have actually become standard practice even before the final debt collection. The tax system has also begun to increasingly take into account not only the tangible assets of a business, but also digital, financial and intellectual resources.
The press service of the Federal Tax Service told Izvestia that interim measures and claims against third parties are being taken based on data from the integrated debt Management and Administration System (ACSAD). It analyzes the taxpayer's risk profile and identifies signs of possible violations, after which the inspector confirms them during the audit.
The tax service stressed that the service relies on debt collection even before the bankruptcy of companies. Thanks to the introduction of a single tax account and automation of procedures, the number of debtors has been halved. Budget revenues from foreclosure measures reached 1.4 trillion rubles in 2025.
They also noted that when abuse is detected, demands can be made not only to the company itself, but also to the controlling or dependent persons to whom the business was transferred. More than 224 billion rubles of debt have already been collected from such individuals using the mechanisms of the ACS.
Who can lose their property rights
The new measures may have the strongest impact on IT companies, brand owners, marketplaces, online schools and media platforms. The reason is simple: the main value of such a business is not buildings and machines, but intellectual property, explained Alexander Khaminsky.
First of all, the risks relate to businesses where the tax service sees large additional charges, signs of fragmentation, withdrawal of assets or questionable transactions with counterparties, explained Evgenia Sabitova from the Union of Lawyers and Bloggers.
At the same time, the Federal Tax Service has more control tools in 2026: electronic checks have been strengthened and the powers of inspectors have expanded. There is still little judicial practice on the seizure of intellectual property, since the rules are new. But the courts have already confirmed the right of the tax service to introduce such measures if there is a risk that the company will not be able to repay the debt, Sabitova recalled.
Lawyers advise businesses to check in advance how the rights to trademarks, software, and other assets are registered. If restrictions have already been introduced, you can try to replace them with a bank guarantee or challenge them in court.
At the same time, the new rules can also be a plus for business, said Roman Umerov from BGP Litigation. If the value of the intellectual property covers the tax claims, the inspectorate may not block the company's accounts completely. Then the business will be able to continue working, settle accounts with partners and accept payments, despite the verification.
How tax control changed in 2026
The Federal Tax Service had previously tightly controlled the collection of tax debts, but now the pressure on business is only increasing, said Natalia Fayzrakhmanova, senior manager of the Kept tax dispute resolution group.
According to her, the checks have become faster and less predictable. Pre-test analysis is increasingly postponed to the beginning of the year, and sometimes field trips are scheduled without it at all.
The subject of control itself is expanding. As explained by tax consultant Alla Milyutina, during on—site inspections, the Federal Tax Service now examines not only classic transactions, but also transactions with intellectual property, especially within the group of companies. The costs of purchasing licenses, programs, and other intangible assets, as well as optimization schemes through related structures, fall under the spotlight. If the rights to such assets are not properly registered or used without contracts, the business may incur additional taxes.
A separate focus is on marketplaces. Starting in October 2026, the sites will be required to transmit data on sellers' revenue, the number of transactions and payments to the Federal Tax Service every month, Roman Umerov recalled. In fact, marketplaces will become part of the control system and will be able to help identify violations.
In general, the Federal Tax Service is increasingly moving into digital supervision. The main goals of the tax authorities now are business fragmentation, "technical" companies, work with the self—employed, marketplaces and cross-border schemes. At the same time, checks are based less and less on paper documents and more and more on analytics and data from information systems.
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