Соглашения об избежании двойного налогообложения: фискальная безопасность государства

Abstract

In today's economy, the basis for optimal tax policy is a holistic approach in the application of international agreements to avoid double taxation. Contracts applicable between jurisdictions are the main instruments for resolving tax disputes and conflicts by taxpayers. The validated double taxation process in each country depends to a large extent on the structure of the tax base, the status of the taxpayer and the established rules for determining taxable income. The object of the study is social relations arising in the field of legal regulation of double taxation. In turn, the subject of study is legal norms, international treaties and agreements regulating social relations arising in the sphere of legal regulation of double taxation. In the practice of international taxation, more than 3000 bilateral international treaties on avoidance of double taxation of personal income and prevention of tax evasion are applied, whereas in Russia, this figure exceeds 80 existing agreements. Under the current legal system, the provisions of double taxation agreements have priority over the provisions of the domestic tax legislation. The analysis of changes in bilateral international double taxation treaties between Russia and Cyprus, Luxembourg and Malta in 2020 allowed identifying important aspects of their legal application and formulating the main tasks necessary for the development of tax potential and successful cooperation in the field of regulation of trade and economic relations.