Colleagues, lately in consultations I keep hearing one "brilliant" scheme. Entrepreneurs who in 2026 are rapidly approaching the critical income threshold reason something like this: "I'll close my sole proprietorship, wait a week, reopen it, and... voila — limits reset, new patents, VAT forgotten!".

Many entrepreneurs mistakenly believe that a new OGRNIP number completely erases their tax past. In practice, in 2026 this logic has become a direct path to huge additional assessments and lawsuits. And here's where it gets interesting. From January 1, 2026, for the patent system (PSN) and VAT exemption, an income limit of 20 million rubles applies. This year's tax campaign is specifically aimed at preventing attempts to "reset" this counter through re-registration. Let's break down why the "closing trick" no longer works.

🤫 The Main Secret You're Missing

Upon re-registration, you will indeed receive new documents, but your individual taxpayer number (INN) remains the same. For the tax service, you are the same entity, and your activities within one calendar year are assessed continuously. There is an important nuance: the Federal Tax Service has already established its position in official letters. If an individual entrepreneur closes and reopens within a year, all income for the entire calendar year is summed up to check the limits for the patent and simplified tax system (USN).

This means that if you earned 18 million before closing and another 3 million after reopening, the tax authority will simply add these figures. Result: the 20 million limit is exceeded, the patent is annulled, and you face additional assessment under the general system or under the simplified system and VAT.

💸 Hidden Traps Businesses Don't Suspect

Technically closing an individual entrepreneur hits the wallet much harder than it seems at first glance.
• Problems with cash registers
Tax authorities automatically deregister the cash register when closing an individual entrepreneur. Upon new registration, you will have to buy a new fiscal drive, as the old one stores only one registration number.

• Loss of expenses
If you purchased goods under the "old" individual entrepreneur and sold them under the "new" one, the Ministry of Finance prohibits reducing tax by these costs. Your expenses from the "old" individual entrepreneur cannot be accounted for, and you will pay tax on the full amount of revenue.

• Double contributions
Re-registration creates a "new" payer. This means the obligation to pay 1% on income over 300 thousand rubles will arise anew, even if you already paid the maximum before closing.

• Account blocks
Your old debts and unfiled reports do not disappear. Old arrears will immediately cause a block on your "new" individual entrepreneur's account, as the debtor database is tied to the INN.


🗺 Migration and Tax Holidays

Many try to close their individual entrepreneur to "move" to a region with a preferential rate or to re-qualify for tax holidays at 0%. Court practice in 2025–2026 is merciless here. If you already conducted business during the period of the benefit, reopening the individual entrepreneur will not make you a "first-time registrant." And if you have no real office or employees in the new region, the tax authority will easily prove the fictitiousness of the move.

In such cases, you will be guaranteed accused of deliberate business fragmentation for tax benefits. Consequences — recovery of all saved taxes plus a fine of 40% of the underpayment amount.

🎯 What's the Conclusion?

You can close an individual entrepreneur and reopen it if you have a real business reason: changing industry, family relocation, or taking a job. But if your sole goal is to escape VAT or retain a patent, know that the risks today are significantly higher than the potential savings.

Sometimes calculating how to work with VAT or legally change your tax regime turns out to be much cheaper than trying to fool the system through "technical closure." Make decisions with a cool head!

If you are unsure how your current business model looks from the tax system's perspective, it's better to check it in advance. During a personal consultation, I will thoroughly analyze your situation, highlight hidden risks, and find the optimal solution for you.

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