The Implementation of BEPS Actions in the Russian Federation

Abstract

The author comes to the conclusion that the development of legal regulation on issues of international cooperation in the area of taxation and the exchange of tax information allows us to positively characterize the process of using the best modern tax practices by the Russian Federation. The main directions of implementation of the BEPS Action Plan in the Russian Federation are considered in the article. The author highlights areas of legal regulation of tax relations, most affected by international economic integration and foreign tax practice. These are CFC rules and tax residence of legal entities, national anti-abusive rules (foremost of which is Article 54.1 of the Russian Tax Code which can be characterized as a new Russian GAAR), thin capitalization rules, administrative assistance and the exchange of tax information. The role of the OECD acts in Russian tax law is brought into light and an analysis of implementation of certain BEPS measures in the Russian Federation is provided. The aim of the article is to show and analyze the ways and perspective of implementation of the BEPS Action Plan in the Russian Federation. The author uses methods of theoretical analysis, particularly the theory of integrative legal consciousness, as well as legal methods, including formal legal method and comparative law. The legal regime of taxation of profit and income in the Russian Federation is influenced by many factors, including the internationalization of tax law.