International Tax Rules in Russia: Conceptual Findings in the Light of BEPS/OECD/G20 Project and Global e-Commerce Developments

24 Pages Posted: 17 Jan 2017 Last revised: 3 Aug 2018

Date Written: December 22, 2016

Abstract

In this paper author compares Russian international tax rules with international “best practice” (incorporated in BEPS deliverables and other OECD and academic reports) with the aim of finding out ways of their improving and development. Main findings include: high level of uncertainty due to existence of distance in applying and interpretation typical international tax concepts (including permanent establishment, VAT place of supply and e-commerce related rules, beneficial owner, transfer pricing and others) between Russia and developed states. Second, some indicators of base erosion were estimated and they showed existence of BEPS behavior in Russia. Third, Russian treaty policy based on concluding OECD-Model treaties and participating in BEPS and implementing new complex anti-abuse rules and recommendations (such as LOB, PPT, CbC, for example) in combination with current court and fiscal practice can harm investment climate and lead to defeat in tax competition game in favor of more developed states.

Keywords: base erosion, distortion of competition, multinational corporations, tax competition, developing country, tax policy

JEL Classification: F23, F62, H25, H26

Suggested Citation

Milogolov, Nikolai, International Tax Rules in Russia: Conceptual Findings in the Light of BEPS/OECD/G20 Project and Global e-Commerce Developments (December 22, 2016). Available at SSRN: https://ssrn.com/abstract=2888857 or http://dx.doi.org/10.2139/ssrn.2888857

Nikolai Milogolov (Contact Author)

Financial Research Institute ( email )

Nastasyinsky Lane, 3, p. 2
Moscow, 127006
Russia

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