The Concept of the Beneficial Owner of the Income in Tax Law of the Russian Federation

The aim of the present graduation thesis is to examine the theory and practice of applying the concept of actual recipient of income in tax law of the Russian Federation, studying of actual approaches of tax authorities to counter the misuse of the bilateral international treaties on avoidance of double taxation, the generalization of theoretical positions and organize a national experience of regulation of this tax law. The graduation thesis consists of introduction, two chapters, 17 sections, conclusions and list of references. The introduction substantiates the relevance of the topic, specifies goals, objectives, subject and object of study. In the introduction the problem this work (in relation to the Russian Federation) is included in the broader context of world practice. Chapter I discusses established the concept of beneficial ownership in the normative practice of the Russian Federation: the existing rights of citizens and organizations lies in the field of tax law. Chapter II is an overview of the law enforcement practice of the Courts of the Russian Federation of different instances in the cases of nedobrosovisnimi using the corporations of the agreements on avoidance of double taxation: the principles of resolving legal conflicts related to the implementation of the activities of the organizations and current trends in judicial practice. On the basis of the study the conclusions about the existing problems in the sphere of tax law and the prospects for their resolution. The volume of the thesis is 60 pages, when writing was used 34 sources.