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International coordination of countries with regards to the problem of dilution of taxation base and reallocation of profits
Abstract.The subject of this research is the international tax relations established between the countries and in need of reforms. The object of this research is the separate position of BEPS Action Plan, such as automatic exchange of financial (tax) information, international documentation on transfer pricing, multilateral instrument of adjusting bilateral agreements on avoiding the double taxation. The article provides a detailed overview of publications dedicated to the subject of research, based on which the author analyzes the object of research, indicating its key development trends and determining peculiarities in the area of national security for Russia. The study demonstrates that the international coordination with regards to the problem of dilution and reallocation of taxed profit, which emerged as a result of transformation of the nature of running international business, suggested a set of instruments on its overcoming that lay the new foundation for further development of the international tax relations between the countries, propelling them to the next level. By implementing such instruments, Russia must consider the opinion of other EAEU member-states and escalation of tension with the Western countries, as well as the current tax climate. Otherwise, there could occur significant risks for the national security.
Keywords: OECD, DTA, Multilateral Instrument, Country-by-Country Reporting, transfer pricing, FATCA, AEoI, BEPS, Federal Tax Service, EAEU
Article was received:19-04-2018
This article written in Russian. You can find full text of article in Russian here .