Amount Of Tax Research Articles

The Impact of Perception of Justice on Tax Compliance Behavior through the Mediating Role of Social Support: An Empirical Study in Pakistan

The government adjusts its financial obligations and collects taxes to pay for the public through taxes. Tax behavior varies from individual to individual. Tax audits and fines are also policies to collect tax amounts. The study aims to determine tax compliance behavior. A quantitative approach is applied to obtain the respondent's perception of justice in tax laws. Overall total number of questionnaires sent to bar councils was 400, of which 325 lawyers responded. The problem is that Pakistan needs a better tax collection system; therefore, many problems are faced during tax collection. The justice system is better for recovering the tax penalties, whereas procedural justice investigates the compliance of individuals about the tax. Taxpayers also find ways to reduce the amount of tax and make deduction claims by hiding some of their assets. Tax audit is also a significant field to assess and measure fraud in the tax collection system. Results differentiate that there is a positive and significant relationship between tax compliance behavior and perception of justice. So, it rejects the null hypothesis and shows a significant relationship. If the individuals cooperate with the government and perform their duties well, then the structure of the tax system can survive and collaborate in the economy of Pakistan.

2022년 주요 상속세 및 증여세 판례회고

There are five major Supreme Court precedents related to inheritance and gift taxes for 2022. In this article, the above five precedents were divided into facts, issues, the position of the Supreme Court, and the significance and evaluation of the judgment in chronological order.
 First of all, the Supreme Court's ruling on March 11, 2022, on whether to invalidate the enforcement ordinance related to Article 41 (1) of the former Inheritance Tax and Gift Tax Act, reaffirmed the position of the Supreme Court's ruling of 2015Du45700 on April 20, 2017 and the Supreme Court's decision of 2019Du35695 on September 9, 2021. The above judgment is valid in that the scope of gifts through corporations is limited through interpretation. However, it is necessary to review whether it is right to follow the materiality and clarity test of the illegality of administrative disposition.
 Second, the Supreme Court's ruling on the taxation and additional tax on the deeming property registered in name of another person to have been donated related to the acquisition of new stocks on September 15, 2022 is about the legal interpretation of the old tax and gift tax law in which the gift tax payer was in principle a trustee at the time of title trust. The target judgment judged that the case in which the title truster acquired new shares as collateral and transferred them under the same person's name, but before the transfer was made, the case in which the loan was repaid with the sale price of the existing title trust shares was not different. From the perspective of sanctions on the total amount of property that is difficult to grasp by title trust, it must be judged as the subject judgment. In addition, it was confirmed for the first time that the subject judgment should be based on the name trustee to determine whether the additional tax is imposed based on the taxpayer. If the above logic is applied to the current tax increase law, it should be judged based on the title truster who is liable for tax payment.
 Third, the Supreme Court's 2022Du33712 ruling on the scope of cancellation of disposition on May 26, 2022 reaffirms the previous precedent (Supreme Court March 28, 1997) that only the portion exceeding the legitimate tax amount should be canceled if the lawsuit for cancellation of the tax disposition exists. It is reasonable in that there is no need to appeal again for parts that exceed the legitimate tax amount.
 Fourth, the Supreme Court's ruling on November 10, 2022, 2020Du52214 is a precedent on whether to recognize self-gifts related to Article 45-3 of the former Inheritance Tax and Gift Tax Act (before amended by Act No. 13557 on December 15, 2015). The above ruling is the first case in which the donor and the recipient cannot be said to be the same, even though the controlling shareholders of the beneficiary corporation are shareholders of a related corporation at the same time. Given that agenda regulations that are disadvantageous to taxpayers need to be interpreted in a limited way, it is necessary to review whether the above judgment is correct.
 Finally, the Supreme Court's decision on December 29, 2022 on the method of calculating gift profits according to the comprehensive exchange of stocks followed the previous precedent (the Supreme Court's decision on March 29, 2018) that gift taxes should be levied by applying Article 42 (1) 3 of the former Inheritance Tax Act. In addition, the target judgment clarified the application of Article 31-9(2)5(b) of the Enforcement Decree of the former Inheritance Tax Act (before amended by Presidential Decree No. 20621 on February 22, 2008), which is the basis for calculating the gift property value of a company that becomes a full subsidiary due to stock exchange.

МІСЦЕВЕ ОПОДАТКУВАННЯ: СУЧАСНИЙ СТАН ТА ДОСВІД КРАЇН ЄВРОПЕЙСЬКОГО СОЮЗУ

The paper examines the formation of local taxation system in Ukraine. It has been established that the number of local taxes and fees has been significantly reduced due to the evolution in the local taxation system. Currently the list of local taxes and fees comprises two local taxes, namely the property tax and the single tax, as well as two local fees including the tourist fee and the vehicle parking fee. It is determined that the basis for local budget revenues is formed by the tax receipts which tend to increase, with the simultaneous decrease in proceeds from state administration bodies. The personal income tax is considered to be the one having the strongest effect on the formation of local budget revenues. The analysis results determine that tax revenues from local taxes and fees have a growing tendency, however they are not budget-forming for the local budgets so far. The overall increase tax revenues to local budgets are observed from the property tax and a decrease in its component – transport tax. Local fees are proved to have a negligible effect on the formation of local budget revenues. It was determined that the local authorities have no power to lay local taxes and fees, preventing them to influence the amount of tax revenues to their budgets. The administration of local taxes and fees is negatively affected by the war, since real estate objects are exempt from taxation, and there observed a decline in the entrepreneurial activity. The insufficient work of local self-government bodies in attracting local taxation opportunities provided by the decentralization reform to strengthen the local budgets financial capacity has been substantiated in the study. It is proposed to strengthen the local self-government bodies’ role in the administration of local taxes and fees, in particular by giving them an opportunity to independently choose the objects of taxation on their territories.

Cluster Analysis Using Principal Component Analysis Method and K-Means to Find Out the Compliance Group of Property Tax

Abstract
 
 The village of Kendal has experienced a decline in local income due to the high rate of property tax arrears, with 226 taxpayers (19% of residents) known to have outstanding payments. Additionally, with 1,159 separate residents residing in 10 block areas with varying tax amounts, it has become increasingly difficult for the Village Apparatus to profile taxpayers based on their characteristics. To overcome these problems, a data analysis model based on Machine Learning technology will be developed using the Principal Component Analysis (PCA) Method combined with the K-Means method. The objective of this study is to create a cluster analysis model that can accurately map the characteristics of taxpayers, making it easier for the Village Apparatus to identify and assist residents who need to pay their property tax. This proposed solution will also simplify the reporting process to the central government regarding the estimated regional revenue sourced from property tax.

Pengaruh Beban Pajak, Mekanisme Bonus, Exchange Rate, dan Intangible Asset terhadap Keputusan Transfer Pricing

Business development encourages companies to grow into multinational companies whose activities are not only centered on one country. In transactions carried out by multinational companies, it is possible for companies to manipulate transfer prices (transfer pricing). The practice of transfer pricing is carried out with the hope of reducing the tax burden and also minimizing the amount of tax that must be paid to the State. The purpose of this study is to determine the effect of the tax burden, bonus mechanism, exchange rate, and intangible assets on manufacturing companies listed on the Indonesia Stock Exchange during the 2018-2021 period. The sample selection method used was purposive sampling method and obtained a sample of 72 research data. The data analysis technique used is multiple regression analysis using SPSS 25 as a statistical tool for testing the hypothesis. The result of this studi indicate that the variable tax burden, bonus mechanism, and exchange rate have no effect on companies making transfer pricng decision. Meanwhile, the intangible assets variable has a significant influence on transfer pricing decisions.

Reforming the Tax on the Property of Individuals

The article examines the historical aspects of taxation of the property of individuals in the Soviet Union and the Russian Federation. The issues of determining the object of taxation and its assessment are considered. At all times, immovable property belongs to the object of taxation. This object is almost impossible to hide and evade tax. Property tax has always been calculated based on its value. The procedure for determining the value changed as well as the list of objects subject to tax. It is noted that the tax on the property of individuals has a great impact on the relationship between the tax payer and the state, when making any changes that increase the amount of payment, it is necessary to take into account the interests of not only the state, but also citizens who pay taxes. If there is an object of taxation, the payment of tax does not depend on the availability of the source of payment. The analysis of personal property tax receipts in the Russian Federation and the Irkutsk region was carried out. Based on the analysis, the conclusion is formulated that the tax on the property of individuals is not particularly important in the formation of municipal budget revenues at the present time. According to this tax, there is a large list of benefits that exempt from paying tax in full or reduce the amount of tax. When establishing the procedure for calculating taxes and tax benefits, it is proposed to take into account the location and destination of property owned by individuals.

Voting Yes for Funding Public Parks: The Effectiveness of Social Media Communication in a Tax Referendum Campaign

Although local park and recreation agencies rely on various types of funding, tax-based allocations are the most significant funding source. Unfortunately, tax-based allocations have not kept pace with growing user demands and maintenance backlogs. As such, successful tax referenda are becoming critical for sustained operations and capital investment. Among the various activities that may sway public opinion, strategic messaging through a variety of media may be one of the most important. Using a county-level public park agency’s 2020 tax referendum as a case study, the purpose of this study is to identify successful communication strategies of open space referendum campaigns that secure support from voters. Data were collected from the campaign’s official Facebook page to examine what message content and post type were effective in increasing voter awareness and engagement. Results from regressions showed that messages that explained the ballot in plain language (e.g., Simplify Ballot Language), demonstrated support or approval from local organizations or local champions/celebrities (e.g., Endorsement), broke down the total amount of tax being requested (i.e., Temporal Reframing), and empha-sized the direct benefits if the referendum were passed (i.e., Direct Outcome) were most effective in increasing the awareness of the referendum. Among Facebook page followers, posts that demonstrated campaign efforts/activities (i.e., Demon-stration) and acknowledged individuals’ or organizations’ efforts to support the campaign (i.e., Acknowledgement) effectively increased engagement. In terms of Facebook post types, photo posts and video posts generally performed better than link and shared video posts. The study has three main practical implications for open space referenda advocates and managers concerned with campaign commu-nication: (1) solicit and demonstrate support from highly regarded local organiza-tions or individuals; (2) emphasize the direct benefits and break down the total amount of tax being asked; and (3) use short videos and scenic images.

Increasing Tax Collection in African Countries: The Role of Information Technology

AbstractMany African countries struggle to collect an adequate amount of tax revenue to support needed investments in public services. This paper examines how African countries may take advantage of recent advances in technology to improve tax administration. It provides an overview of the potential and challenges of different tax categories in Africa: consumption taxes, real estate taxes, trade taxes and income taxes. It then describes the ways in which technology solutions may be deployed to address these challenges by helping to identify the tax base, monitor compliance and facilitate compliance. Lastly, it provides insights from interviews with senior tax administrators across the continent on their practical experiences in adopting technology for taxation.

Study Literature Review of the Rise of Tax Avoidance Practices

This study aims to find out how many companies are trying to avoid taxes. This research was conducted by observing a number of papers, namely by documenting various articles related to tax avoidance and then adapting them according to several categories until finally there were 313 articles that could be used. Initially there were 644 articles, then adapted based on the selection of abstracts and several inappropriate criteria so that the number became 404 articles, and then read again until finally there were 313 articles that could be examined. In this study, the fact is that many companies are trying to avoid taxes, utilizing the services of tax consultants in order to reduce the amount of corporate tax that must be paid. In addition, the company always tries to use a variety of very subtle techniques so that the tax authorities cannot find out, there is a very significant difference in relation to carrying out tax evasion by taking advantage of loopholes in the law compared to carrying out illegal tax evasion and this will certainly lead to new problem for the company. Thus, the urgency of paying taxes will always be supervised and monitored by the government due to certain targets in an effort to increase the realization of tax revenues every year.

Does inheritance taxation reform promote to build inexpensive rental housing?

The inheritance taxation reform of 2015 in Japan substantially increased the amount of tax levied on large inheritances. This potentially served as a good incentive for people to build inexpensive low-rise apartments for tax savings, which increased the number of low-cost apartments. Therefore, this study investigates the effect of inheritance taxation reform on housing rents. Using the difference-in-differences method, we reveal that the inheritance taxation reform decreased the housing rents of wooden or light steel-framed apartments by 1.3%. Moreover, our results indicate that while the rental of slightly older housings belonging to the treatment group decreased, the rental of new housing belonging to the treatment group did not change.

Changes in sugar-sweetened beverage purchases across the price distribution after the implementation of a tax in Mexico: a before-and-after analysis

BackgroundA tax of one-Mexican peso per liter of sugar-sweetened beverage (SSB) came into effect in January 2014 in Mexico as a national health policy to tackle the high overweight and obesity prevalence. Previous studies have shown an overall reduction in SSB purchases after the tax implementation. However, it remains unknown whether and to what extent SSB consumers switched to cheaper taxed beverages, attenuating the potential effect of the policy. Our study’s objective was to estimate changes in household purchases of taxed SSBs by tertiles of SSB prices (low, middle, and high) in urban areas after the SSB tax implementation in 2014.MethodsBased on purchase data for 2012–2015 from households living in 54 Mexican cities with a population > 50,000 inhabitants, we calculated unit-value SSB prices for the full period and sorted them on a monthly basis to create monthly price tertiles. We merged these price tertiles to household purchases and created average monthly ml/capita/day SSB purchases by price tertile at the city level. We assessed SSB purchase switching patterns before and after the tax implementation through price-tertile stratified linear models. The main variable in the models was a dummy indicator that allowed us to identify the pre-tax period (2012–13) and post-tax period (2014–15). We controlled our models for time trends and contextual economic variables.ResultsIn the regression adjusted models, we found a statistically significant purchase reduction ranging between 10.80 and 13.79 ml/capita/day (p-value < 0.001) across taxed beverages from the middle-price SSB after the tax implementation. We observed no statistically significant reductions in purchases of low-price SSBs and high-price SSBs.ConclusionsOur findings show purchase reductions in the middle-price SSBs, which represents ≈30% of the overall SSB purchases in urban Mexico. Future studies should be conducted to test if the redesign of the current the tax, by either doubling the tax amount or taxing sugar content, might reduce more effectively purchases across all SSBs.

IMPLICATIONS OF THE PROPOSED COMPREHENSIVE CHANGES IN FORM GSTR-3B ON TAX COMPLIANCE

Tax compliance through filing of GST returns is a critical process because it authenticates tax payments, qualifies for input tax credits and ensures timely tax refunds. For this purpose, the Government has introduced various forms under GST law, including FORM GSTR-3B[1]. It is a summary return that was initially introduced as a temporary return to collect the tax amount from the taxpayer. However, it is designated as a default return on the advice of the GST Council. Considering the shortcomings of the existing GSTR-3B, discussions on comprehensive changes in Form GSTR-3B were held in the 47th Meeting of the GST Council on June 28 and 29, 2022, and the concept paper on comprehensive changes to Form GSTR-3B is published for public review to solicit views, comments, and suggestions2 . This research paper is an attempt to review the proposed changes in Form GSTR-3B, gauge their implications on tax compliance by the taxpayers and propose measures to strengthen GST compliance.

Effect Size of Land, Building and Number of Taxpayers of Land and Building Tax Revenue in The District of Pandeglang

Tax is one important element in the government finances , and a source of government funding that will be used to finance the country's infrastructure and local There are different types of taxes imposed to society, but one of the taxes collected by local governments as local revenue is tax and buildings. Property tax is a tax levied on immovable property consisting of land and buildings owned by the taxpayer . This study aims to determine the effect of Land, Buildings and Total Number of Taxpayers against Tax Receipts Earth And Building in Pandeglang. This type of research is quantitative research with secondary data obtained from Revenue Pandeglang. The sample used in this study is the total sample or sampling saturated. as expressed by Sugiyono (2010) that "the saturation sampling is sampling technique when all members of the population used as a sample ". The sample in this study were all districts in Pandeglang number of 35 districts. Analysis of data using multiple linear regression and to determine the hypothesis used t test and f. In this study, researchers took the period 2013-2015, as for the type of data used is secondary data . Data obtained from the Department of Revenue (DISPENDA) Pandeglang. Testing the hypothesis in this study using correlation and multiple linear regression with t test and f test at the 5\% significance level ($\alpha$=0.05). The results showed that the variables of land area, the number of buildings and the number of taxpayers together affect the acceptance of the United Nations. The greater the amount of land area, the number of buildings and the number of taxpayers, the land and building tax receipts will increase because reception is directly proportional to the amount of land and building tax (PBB).

DEVELOPMENT OF THE TAX ADMINISTRATION SYSTEM OF BUSINESS ENTITIES OF UKRAINE

The paper presents systemic and process approaches to the description of the tax administration system of business entities in Ukraine. From the point of view of the systemic approach, tax administration is a system that, in its elementary form, consists of a subject of management, an object of management and the connections between them, through which management influence on tax legal relations is exercised by persons whose main job duties are making decisions and communicating them to subordinates. Based on known models of system-oriented management of organizations and their individual elements, the following components can be distinguished in the system designed to ensure compliance with tax legislation: system input represented by financial, material, immaterial and labor resources; controlling and managed subsystems, as well as the output of the system in the form of economic and social results of activity, added tax amounts, official and unofficial information, training and development of employees, ensuring the safety of social interaction, etc.&#x0D; From the point of view of the process approach of tax administration, administrative activities carried out by tax and other controlling bodies are regulated by laws and other regulatory legal acts.&#x0D; The beginning of the full-scale invasion of Ukraine by the russian troops became the starting point for the emergence of a number of problems in the system and processes of tax administration in our country, which are related to the loss of legal personality by taxpayers, their complete or temporary loss of taxation objects, registration changes, technical impossibility of registration of business operations and communication with controlling bodies, etc. It was determined that the solution to most of the mentioned problems lies in the area of taxation, that is, the adoption of laws forming the tax system. We believe that the tax burden on business in Ukraine should be reduced and the tax administration process simplified for the next five years after the end of war on the territory of Ukraine in order to restore national business as soon as possible and attract foreign investors.

Tax effect of digital economy development in China: The policy effect and transmission mechanism

&lt;p&gt;&lt;big&gt;The development of digital economy is becoming an important path to promote the kinetic energy of China&amp;#39;s tax revenue development. Based on the panel data from 2011 to 2018, this paper uses Gini coefficient to analyze the regional differences of China&amp;#39;s digital economy, and uses fixed effect model, spatial Durbin model, multi-period double difference model and other empirical methods to examine the tax effects of digital economy development. The results show that the regional disparity is the main reason for the regional disparity of digital economy development in China. The development of digital economy directly increases the tax amount of local digital industry, and at the same time it also radiates and drives the increase of local total tax revenue; The tax effect of digital economy has a negative spatial spillover, showing a &amp;quot;siphon effect&amp;quot; to neighboring areas; Mechanism analysis shows that the development of digital economy mainly promotes the increase of local tax revenue through growth effect.&lt;/big&gt;&lt;/p&gt;

PENDAMPINGAN PERPAJAKAN PADA USAHA MIKRO, KECIL, DAN MENENGAH DI KABUPATEN KUDUS

In 2017, the MSME sector in Indonesia has a role of 60.34% of GDP formation. However, the magnitude of the contribution of MSMEs is not accompanied by its contribution to tax revenues. The PKM target audience is MSMEs in Kudus Regency. There are still many conditions for MSMEs in Kudus Regency who do not yet have an understanding of taxes, do not know about the implementation of PP No. 23 of 2018 concerning MSME tax, do not understand the importance of financial records, calculate the amount of tax and do not know how to make a tax report. The solution offered in this PKM is to provide information about PP No. 23 of 2018 and provide assistance on financial records, calculations and tax reporting for MSMEs. The purpose of this PKM activity is 1) to provide understanding and knowledge to MSME actors in Kudus Regency about taxation, 2) to provide awareness about the importance of taxes for MSMEs, 3) to increase understanding for MSME actors regarding PP No. 23 of 2018, and 4) provide an understanding of the process of recording finance, calculating the amount of tax to be paid and making tax reporting. The problems in this PKM will be solved by stages of activities, namely: training, discussion and practice.

Methodology for assessing the effectiveness of the tax base among redistribution the largest taxpayers

Purpose: the article is aimed at presenting the author’s methodology for evaluating the efficiency of redistribution of the tax base within the consolidated group of taxpayers (hereinafter REAG) the construction of which is based on the determination of relationships and assessment of the degree for influence of tax deductions on the operating profit of the enterprise.Methods: in the part of the study of the tax base and REAG contributions, methods of applying statistical analysis were used, including the study of the structure and dynamics of tax payments of the enterprise. As part of the construction of the model, this article provides the correlation and regression analysis, providing for several stages related to the application of the specific tax regime of REAG as the significant factor of influence on the process of distribution of the taxable base of the organization. The data of public joint-stock company «Oil company «ROSNEFT» were used to assess the influence on the operating profit of the enterprise of the taxes paid. The graphical analysis was used to visualize the data.Results: in the course of the study, the degree of influence of the volume for sales of products, selling prices, decrease of the cost and changes in the sales structure on the volume of tax payments of the enterprise was assessed. These factors determine the effectiveness of the REAG’s tax regime, as they represent the company’s profit and therefore affect the amount of income tax. This dependence is reflected in the developed econometric model, which determines the share of each factor in the total income tax of the enterprise, which allows to optimize the tax base of the organization in the future.Conclusions and Relevance: the analysis revealed the need to improve the efficiency of income tax payment. In response, the methodology for improving the tax regime is proposed. Tax optimization measures include two directions: the process of redistribution of the tax base and the extension of the term for performance of tax obligations within the combined group (from earlier to later). These measures will reduce the risks of taxpayers.

МЕТОДОЛОГІЯ ВИЗНАЧЕННЯ РОЗМІРУ ЕКОЛОГІЧНОГО ПОДАТКУ ЗА ВИКИДИ В АТМОСФЕРНЕ ПОВІТРЯ ДВООКИСУ ВУГЛЕЦЮ

This article is devoted to current problems of environmental protection. Environmental taxes (payments) are the most effective tools that can be used to regulate relations between the state and polluters, as well as to stimulate polluting enterprises to ecologization their production. Objective. The purpose of the paper is to develop a methodological approach to determining the amount of the environmental tax for emissions of carbon dioxide into the atmosphere. Research methods. The purpose of the research is achieved with the help of general scientific methods (analysis of statistical data, synthesis, generalization) and special methods (collection of information, its processing, conducting analytical work, methods of calculations and justifications). The volumes of carbon dioxide emissions into the atmospheric air were analyzed. Among the methods of conducting analytical work, the comparison method was used - to compare the amount of the environmental tax determined by us for emissions of carbon dioxide into the atmosphere with similar environmental tax rates applied in the European Union. Obtained results. A methodological approach has been developed to determine the amount of the environmental tax for carbon dioxide emissions into the atmosphere. The amount of the environmental tax for carbon dioxide emissions into the atmospheric air is determined by the cost of forest ecosystem services for the absorption of carbon dioxide, the annual costs of enterprises for the ecologization of production, the volume of carbon dioxide emissions into the atmospheric air from stationary and mobile sources in Ukraine, the annual volume of carbon dioxide absorption by forest ecosystems from atmospheric air. Our research is complete and includes both an economic and an ecological component, which characterize the state of atmospheric air pollution with carbon dioxide. Using this methodology, we made calculations and obtained economically justified amounts of environmental tax. In terms of its economic significance, such an ecosystem payment is not a new tax and does not contradict the current legislation of Ukraine. Data for calculations are taken from the real economy in the environmental sphere. The amount of such an environmental tax, obtained on the basis of our methodology, correlates with the amounts of taxes for emissions of carbon dioxide into the atmospheric air, which are currently used in European countries. We received the economically justified amount of the appropriate environmental tax. It is thanks to real statistical data that our obtained indicators

THEORETICAL FRAMEWORK OF INTERRELATIONSHIP’S INNOVATIONS, BRANDS OF COMPANIES AND TERRITORIAL DEVELOPMENT

The territorial development is connected with innovative activities of companies. The intangible assets, in particular, brands of companies, form an additional factor in strengthening the impact of innovation on the territorial development, and thus increases the efficiency of the latter. The aim of research is to develop the theoretical framework of itinterrelationship’s innovations, brands of companies and territorial development. It was used methods of analysis, synthesis and system approach. It was found, that the main indicators of the interrelationship’s framework "innovations-brands of companies-territorial development" are: 1) innovative indicators of companies: the number of innovations, the number of implemented innovations, the number of patents; 2) financial and economic indicators of the company: expenses for the promotion of the company, brand value, revenue, taxes; 3) indicators of the territorial development: the budget of the territory, the GDP of the territory, the number of business entities located in the territory; the number of business entities registered in the territory. More innovative companies have a higher brand value, realized in higher demand for products, increased revenue, and, therefore, the amount of taxes that come to the territory's budgets. A larger territory budget determines the regional economic capacity, expanding opportunities and directions of development.

Экономико-аналитический подход к оценке налоговых рисков отсутствия фактического права на доход

The subject of the study is the identification by the tax authorities of the dependence of the jurisdiction of the location of the parent companies of Russian organizations on the amount of additional charges for corporate income tax withheld at source in Russia, while controlling the actual right to income (FPA) of a foreign organization. The purpose of the work is to develop proposals for tax risk management in determining the FPA. The article, in conjunction with the analysis of the dynamics of foreign direct investment from Russia, analyzes information on changes in the amounts of corporate income tax paid when paying passive income to foreign recipients, as well as data on the amount of additional tax when monitoring the status of the FPA. As a result of the analysis of court decisions on the basis of the "geography" of the beneficial owners of income from the Russian source, the relationship between the jurisdiction of registration of parent companies of taxpayers and the average amount of additional corporate income tax due to non-compliance with the status of the FPA was established. It is concluded that in the overwhelming majority of tax disputes on the status of the FPA, foreign companies – recipients of income were recognized by the courts as conduit companies created to take advantage of registration in low-tax jurisdictions and abuse the provisions of international tax treaties. It was revealed that over the past seven years, the reason for the outflow of capital from the country was the desire of taxpayers to reduce the effective tax rate by withdrawing profits to low-tax jurisdictions, in which large firms prefer Singapore for structuring cash flows in most cases.