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Features of Taxation of Controlled Foreign Companies' Profits

ФИО студента: Gorovtsova Svetlana

Руководитель:

Кампус/факультет: School of Law

Программа: Law and Public Administration (Master)

Год защиты: 2020

This work is devoted to the consideration of one of the mechanisms aimed at deoffshorization of the Russian economy, namely the CFC rules. The CFC rules were born in the USA, and every year more and more countries accept them. Russia was no exception either.  Despite the fact that there are only seven articles devoted to CFC rules in the Tax Code of the Russian Federation, there are even some gaps in them. More attention is also paid to the relationship of this mechanism with the institution of corporate tax residence, as well as issues related to the exchange of information for the purposes of the CFC. However, the thought of the world community is not standing still and therefore it is also important to consider further ways of developing CFC rules within the Global Anti-Base Erosion (Pillar Two).

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