Abstract: The subject of this article is the set of legal norms of the Russian Federation, Germany, Romania, and the United Kingdom that regulate relations in the field of taxation, the complex of theoretical works on the research topic, as well as model documents of the OECD. The prospects for the introduction of a global minimum tax in the Russian Federation are considered within the framework of the current complex foreign policy situation, with the need to stimulate economic and business activity in the territory of the state and ensure technological development. The research subjects also include legal norms and laws regulating the establishment and functioning of preferential taxation zones and investment contracts, as well as mechanisms for protecting investors and economic actors from changes in fiscal regulation and promoting business activity. Potential consequences for Russian corporate groups arising from the introduction of a global minimum tax in foreign jurisdictions are particularly examined. This work was conducted using comparative legal methods and critical analysis methods. General scientific methods (generalization, description, systemic method) were employed, as well as specific legal methods such as formal legal method and the interpretation of regulatory legal acts. The scientific novelty of this work arises from a comprehensive analysis of the main challenges faced by Russia in the context of global tax reform. The key mechanisms of the OECD Model Rules and the potential for adapting Russian tax legislation to introduce a global minimum tax were considered. A comparative study was carried out regarding the OECD's approach to assessing the level of corporate tax liabilities, Russian measures to protect the tax base, and measures to stimulate business activity and redomiciliation. Conclusions were drawn about the need to incorporate provisions into bilateral agreements on the avoidance of double taxation and information exchange with friendly jurisdictions, as well as to align the current provisions of the Russian Tax Code with the OECD approach. These conclusions can be utilized in practice. Changes to the legislation were proposed to ensure the operation of information exchange systems and the potential introduction of a global minimum tax at the national level in Russia.

Keywords: global minimum tax, Russia, OECD, erosion of the tax base, minimum level of taxation, tax preferences, preferential tax zones, investment contracts, information exchange, transfer pricing