The concept of "Beneficial Owner" for the Purposes of Application of Russian Federation's International Tax Conventions.

This master's dissertation is devoted to the study of the legal concept "Beneficial owner" (hereinafter – the Concept). The purpose of this research paper is to elaborate an approach for the application of the Concept, primarily, in the Russian Federation. This dissertation clarifies the essence and purpose of the Concept and describes the history and circumstances of its emergence. The study considers the problems of the legal understanding of the Concept, as well as the issues of the legal regulation of the Concept. This research also analyses the place of the Concept in the system of anti-abuse rules and studies its interaction with other general and specific anti-abuse rules. In addition, this dissertation studies the criteria that identify the beneficial owner of income, the limits of the operation and specific features of the application of the Concept and other issues related with the Concept. As a result of the study, it was concluded that the development of unambiguous approaches to the issues addressed in the study and / or clear legislative regulation would facilitate a more justified application of the Concept from a legal point of view. This study is, in our opinion, of great practical importance, since it will contribute to the formation of uniform, clear approaches to understanding and applying the Concept and other related issues that provide legal certainty and stability that will help reduce tax disputes on this subject and improve the quality of tax disputes through strengthening the positions of tax authorities and taxpayers. Improving the quality of arguments on both sides of tax disputes will contribute both to proper protection of the fiscal interests of the state on the one hand, and protection of the interests of taxpayers on the other.