Abstract

This article discusses such legal regulation tools as: double taxation avoidance agreement (DTA), the concept of the actual right to income (ARI), which are used in the process of profit repatriation by Russian companies. The relevance of the study is expressed in the fact that in connection with the tightening of tax legislation and the deterioration of the external economic situation, Russian oil and gas companies need to look for ways to reduce the tax burden. The aim of the study is to consider the possibility of using the above tools on the example of a real project “Dunga PSA”. The objective of the study is to analyze the methods of legal regulation of the repatriation of income and methods of their application in practice.

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