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Prospects of the International Coordination of Approaches of BRICS Countries to Cross-Border Taxation
Abstract.The authors of the article focus on some prospects of the international coordination of approaches of BRICS countries to cross-border taxation and other cross-border economic relations. In particular, the author analyzes the issues that arise during the development of the BRICS Multilateral Double Taxation Avoidance Convention in relation to particular revenues of small- and medium-sized businesses (based on using the method of release of certain extraterritorial revenues of taxation) and BRICS Multilateral Convention that regulate cross-border tax disputes (on the basis of implementation of mediation elements and tax arbitrage for particular categories of tax cases). In addition, the authors of the article evaluate prospects for the convergence of financial and taxation systems of BRICS countries and establishment of general and special measures of tax abuse prevention, taxation rules of controlled foreign companies, procedures to prove fiscal residence and rules for the implementation of tax treaties during taxation of sources of income and particular rules of taxation of permanent establishments.
Keywords: cross-border tax disputes, tax mediation, tax abuse, avoidance of double taxation, tax exemption, controlled foreign companies, permanent establishment, BRICS multilateral conventions, cross-border taxation, international tax law
Article was received:06-12-2018
This article written in Russian. You can find full text of article in Russian here .