Development of the concept of permanent representation as a tool to increase the "tax" attractiveness of the Russian economy

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The object of this study is the taxation of profits and incomes of foreign companies in the context of the institute of "permanent representation", the subject is the problems of collecting mandatory payments and the transformation of the institute in the conditions of digitalization of the economy. Within the framework of the article, the authors analyze the nature of a permanent establishment as a certain characteristic of a subject of tax law based on foreign experience. When revealing the objective reasons and prerequisites for the need to transform this institution, an analysis is also carried out based on the subjects of world economy and the theoretical approach of domestic researchers of such a transformation option as the introduction of the definition of "digital permanent representation". As a result of the study, the authors come to the conclusion about the need for qualitative changes in Russian tax law in terms of the regulation of permanent representation: its definitions, definitions of a single approach to a single technological process and the need to introduce the institute of digital permanent representation. When studying this problem, qualitative theoretical and practical analyses were carried out. The scientific novelty of the study consists in substantiating the existence of significant problems in the regulation of taxation of profits and income of foreign companies operating in Russia, in particular, through permanent representative offices, and proposals for their elimination.