Abstract
The purpose of the article is a comprehensive study of the problems of double taxation, which is at the intersection of categories of taxable entity and taxpayer. According to the purpose, it is substantiated that double taxation arises in the case of taxation of income received by residents abroad, or in the case of a mixed procedure of tax payment, or in the taxation of the distributed part of the profits of enterprises. It has been established that double taxation is also possible with the partial imposition of one object on another, and this can occur both within the same country and under different tax systems. The taxation of petroleum products with excise tax, which resulted from the legislative regulation that led to double taxation, was considered and analyzed. In the process of researching the topic of the article, the authors conclude that, starting from 2016, the legislator actually introduced double taxation with the same tax and accordingly replaced the ad valorem excise tax rate on retail sales of excisable goods with specific ones (Euro tax rate per unit of tax). It is stated that double taxation of one and the same taxpayer is a violation of Article 1 of the Protocol to the Convention for the Protection of Human Rights and Fundamental Freedoms of each natural or legal person, the right to peacefully own their property.
Highlights
The relevance of the topic is due to the theoretical and practical importance of research into issues related to double taxation
It should be noted that there are several types of double taxation, among which are: internal double taxation and external taxation, which face national legislation in determining tax or payer, treating him or her as a liable person by analogy with the law of another state
Achievements of the set goals and objectives within the chosen topic of the article are based on the set of scientific methods of philosophical, general scientific and special scientific levels
Summary
The relevance of the topic is due to the theoretical and practical importance of research into issues related to double taxation. External double taxation issues are resolved through the conclusion of international bilateral or multilateral agreements. The origin of double taxation is, as a rule, different legislative regulation of the payer and sources of income in the legislation of different states. There are two ways to eliminate double taxation. This is usually one-sided (a change in national tax law) or bilateral (based on international agreements by bringing national tax laws into conformity)
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