State Tax Policy in the Field of Personal Income Taxation in the Context of the Application of Double Taxation Treaties

With the development of intergovernmental cooperation, countries of the world community become participants in international tax relations, in which the questions of the double taxation arise. Tax treaties aim to address issues related to double taxation, as well as other tax barriers which can act as a deterrent to cross-border movement of human capital, investments and technology. The specificity of the application of tax agreements on the avoidance of double taxation remains insufficiently studied, which not only creates a gap in legal science, but also generates numerous risks for the economic activity of taxpayers. The purpose of this paper is to analyze the actions of the legislator in the context of the application DTTs on the personal income, as well as to attempt to formulate the main problems that arise in the case of double taxation of personal income, as well as to study the difficulties faced by taxpayers and Russian tax authorities in applying mechanisms and rules related to double taxation, to analyze the existing weaknesses of the Russian system in relation to this phenomenon and identify possible solutions to existing problems. In order to achieve this goal, the present study examined publications on the topic of double taxation and its elimination, analyzed the main directions of the tax policy of the Russian Federation, as well as the actions of the legislator aimed at the application of the DTTs in relation to the personal income, identified the main gaps and shortcomings of the practical application of the DTTs, which mainly consist in a complex bureaucratic system and the expensive process of preparing the necessary documents for taxpayers to avoid double taxation. As a result, study indicates that urgent solutions are required not only for international cooperation of tax authorities, but also for the development and improvement of existing legislation on the elimination of double taxation in Russia in order to achieve the principle of fairness taxation of personal income in Russia.