О многосторонних налоговых соглашениях: первый компонент ОЭСР и налоговая политика России

Abstract

This article is devoted to the prospects for the development of the OECD’s Pillar One through the proposed principles of the distribution of tax rights between the participating countries. Achieving this goal involves reviewing the experience of using multilateral tax treaties, carrying out a critical analysis of the provisions of the OECD’s Pillar One, including for compliance with the principles of distribution of tax rights laid down within OECD’s Pillar One, the fundamentals of Russian tax policy. Based on the experience of the administration of multilateral tax treaties, the authors found that their effectiveness directly depends on the harmonisation of the economic interests of the participants and the formation of internal consistency of the provisions. Using a set of general scientific methods it was revealed that the principles of distribution of tax rights used in the OECD’s Pillar One may not fully meet the interests of the participating countries, creating a significant potential for the occurrence of tax disputes. Based on this, from the standpoint of a systematic approach, the authors have identified both the advantages and risks of Russia’s potential accession to the OECD’s Pillar One.