History of Origination of the Principle of Legitimate Expectations

The article examines the process of forming the principle of legitimate expectations within the framework of the civil law and common law by analyzing scientific doctrine and key court decisions on the example of the Federal Republic of Germany and the United Kingdom of Great Britain and Northern Ireland. The dynamics of the content of the principle of legitimate expectations is presented, as well as an assessment of the prospects for its application in resolving tax disputes. As a result of the conducted research, the author comes to the conclusion that it is necessary to further develop and study foreign experience in implementing the principle of legitimate expectations in order to form the boundaries and criteria for its application in the tax law of the Russian Federation.