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Legal Regulation of Taxation of Controlled Foreign Corporations' Income in Russia and the UK

Student: Firstova Valeriia

Supervisor: Mikhail Orlov

Faculty: Faculty of Law

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

Year of Graduation: 2017

Theoretical and practical issues of taxation of controlled foreign corporations' (further - CFC)income are considered in the paper. These rules are used as a measure of combatting with tax avoidance through accumulation of income in "low-tax" jurisdictions. The author analyzes the concept and common approaches of formalizing of CFC rules, which have been worked out in international tax practice based on the reasons caused their existence. The author draws the reader's attention to the role of the OECD in forming of core standards of CFC rules. Separate chapter is related to the comparison of CFC rules established in Russia and the UK. As a result of the research the author tries to summarize, which country has more distinct and effective CFC rules in terms of the OECD's standards.

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