Abstract: This article is dedicated to identification and analysis of the gaps in legal regulation of profit taxation of controlled foreign companies (CFC) in the Russian Federation, by comparing the Russian legislation with the legislation of the European Union member-states. Comparison is conducted on the current legislation of the Russian Federation on CFC with analogous rules in France, Germany, Netherlands, and Great Britain. The author determines the similarities and differences in the regimes of profit taxation of controlled foreign companies, and substantiates the need for introducing point amendments to the current legislation of the Russian Federation on profit taxation of controlled foreign companies. The structure of the Russian rules on CFC is largely similar to such in the developed European countries. The definition of the concept of control in the Russian legislation for the most part aligns with the definitions of the analogous concept in the legislation of France, Germany, and Netherlands; although the Russian definition is certainly broader, as it applicable to foreign structures without formation of legal entity, and contains both quantitative and qualitative criteria. Despite formal similarity of the Russian rules on CFC and their foreign equivalents, there are gaps in the Russian legislation, the interpretation of which by the tax authorities and the Ministry of Finance is at times contradictory and often does not benefit the taxpayer. Numerous questions arise from filling out and submitting participation notices and CFC notices, the procedure for which also contains multiple gaps, and the grounds for their submission in the legislation are quite ambiguous. Taxpayers often do not timely notify the tax authority on the participation in CFC or do not submit the corresponding notice due to inaccessibility of software for filling out notices for companies established in particular organizational-legal form.