TY - JOUR

T1 - Reform of International Taxation in Russia

AU - Kilinkarova, Elena

PY - 2020/9

Y1 - 2020/9

N2 - This contribution deals with signifi cant changes in regulation of cross-border taxation in Russia that have been introduced since 2014 mainly due to the impact of the governmental policy of deoffshorization aimed at fighting the offshore character of Russian economy. At the same time participation in the OECD BEPS Project also infl uenced the international tax landscape in Russia. The analysis of the key substantive and procedural rules that were introduced in the course of the international tax reform in Russia is the key goal of the article. The author covers controlled foreign companies rules, management test for corporate tax residence, beneficial ownership concept, automatic exchange of information and key changes in the tax treaty network. The author aims to show steps that were taken by Russia in its reform of international taxation in order to confi rm the hypothesis that in cross-border taxation Russia uses the widespread mechanisms and soft law recommendations while going its own way and often setting its own versions of the main elements of the international taxation landscape. Another important issue under consideration is the balance between unilateral, bilateral and multilateral regulation of international taxation in Russia.

AB - This contribution deals with signifi cant changes in regulation of cross-border taxation in Russia that have been introduced since 2014 mainly due to the impact of the governmental policy of deoffshorization aimed at fighting the offshore character of Russian economy. At the same time participation in the OECD BEPS Project also infl uenced the international tax landscape in Russia. The analysis of the key substantive and procedural rules that were introduced in the course of the international tax reform in Russia is the key goal of the article. The author covers controlled foreign companies rules, management test for corporate tax residence, beneficial ownership concept, automatic exchange of information and key changes in the tax treaty network. The author aims to show steps that were taken by Russia in its reform of international taxation in order to confi rm the hypothesis that in cross-border taxation Russia uses the widespread mechanisms and soft law recommendations while going its own way and often setting its own versions of the main elements of the international taxation landscape. Another important issue under consideration is the balance between unilateral, bilateral and multilateral regulation of international taxation in Russia.

KW - tax law

KW - international tax law

KW - controlled foreign companies

KW - benefi cial ownership

KW - automatic exchange of information

KW - MLI

KW - BEPS

UR - https://www.ejournals.eu/FLR/Issue-3/art/17667/

UR - https://www.mendeley.com/catalogue/6bd0ad56-0884-3603-bfe3-45538d5be059/

U2 - 10.4467/22996834FLR.20.012.12747

DO - 10.4467/22996834FLR.20.012.12747

M3 - Article

SP - 20

EP - 35

JO - Financial Law Review

JF - Financial Law Review

SN - 2299-6834

IS - 19 (3)

ER -