Measures of Counteraction Against Abuse of Law in Tax Relationships: by the Example of "Thin Capitalization" Rules

Student: Replianskaia Anastasiia

Supervisor: Mikhail Orlov

Educational Programme: Financial, Tax and Customs Law (Master)

Year of Graduation: 2017

This work represents complex scientific research of such measure of counteraction against abuse of law in tax relationships as “thin capitalization” rules, which are aimed at limitation of possibilities of excessive debt financing drawing from interdependent foreign residents. The first part of MPhil is devoted to definition of the term “abuse of law in tax relationships” and marking out of characteristics of abuse of tax law and abuse of treaties, it also holds comparison of “thin capitalization” and stated above characteristics of abuse. This research also includes an analysis of correspondence of “thin capitalization” rules with separate principles of tax law in the Russian Federation and provisions of international tax treaties and soft law.

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