The article is devoted to the problem of analysis of factors substantiating reasonableness of providing tax benefits for business activities of taxpayers in order to enable transition and application of special tax regimes that give taxpayers significant advantages reducing the size of the tax burden and exempting from payment of basic taxes within the framework of the general taxation system. The study of the issues of unreasonableness of giving tax benefits in the transition and application of special regimes by taxpayers shows that forms of business organization and tax planning should be chosen by the taxpayer in terms of his or her real economic participation in civil transactions with the most favorable tax implications for taxpayers.