Issues of Аpplying the Beneficial Owner Concept in the Russian Federation

The Beneficial ownership concept is a one of a mechanism to eliminate the avoidance of taxes through the abusing of international tax treaty in International Tax Law. This concept was introduced in Russian Tax Code in 2015 like a “beneficial owner of income” concept and have been actively used. Main aims of research were to identify and explain the special characteristics of the Russian approach to understanding and applying the beneficial ownership concept (beneficial owner of income), analyse the connection between Russian and international approach, a revelation topical issues. Conclusions of investigation based on Russian and international legislation, doctrine, courts practice and confirm that Russian understanding of beneficial ownership concept and aim of applying have departed significantly from international practice and Russian court practice is more formal.