Some Issues of Application of Beneficial Ownership Concept

Некоторые вопросы применения концепции фактического права на доход

Machehin, Victor (Мачехин, Виктор) ()
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Machehin, Victor (Мачехин, Виктор): The Russian Presidential Academy of National Economy and Public Administration

Working Papers from Russian Presidential Academy of National Economy and Public Administration

Abstract: The concept of the beneficial ownership on income is one of the most demanded in the practice of international taxation. This concept is one of the most controversial and does not have a common understanding among tax authorities and taxpayers, which leads to numerous tax disputes, including judicial ones. Understanding the nature of this concept is extremely relevant in the context of the sanctions pressure exerted on Russia. The development of theoretical and practical approaches to the nature of the concept of the beneficial ownership on income refers to the purpose of the work, the achievement of which was connected with the solution of a number of tasks, namely: to systematize existing views on beneficial ownership on income, to identify the logic of the emergence and development of the concept of beneficial ownership on income. The recommendations are aimed at improving the working conditions of tax authorities and taxpayers applying the concept of beneficial ownership.

Keywords: international tax agreements; OECD; attribution of income to a taxpayer (search for similar items in EconPapers)
Pages: 28 pages
Date: 2023
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