Abstract: In his research Rakov analyzes the problem of tax avoidance from the point of view of the tax shifting concept from the historical point of view. The subject of the research is the terms 'tax shifting' and 'tax avoidance'. The scope of the research also covers tax avoidance patterns, classifications of tax avoidance, and tax avoidance preventive measures. Within the framework of the research the author views the tax avoidance process as an economic and legal phenomenon. The author examines the grounds for the creation of the tax avoidance preventive regime with regard to the Russian environment of the late XIXth - early XXth centuries. In the course of writing this article Rakov has applied historical method, comparative law, formal law methods, formal law, hermeneutics, synergetics, inductive and modelling research methods. The comparative analysis of the Russian and Western European approaches to the tax avoidance issue at the turn of the XIXth - XXth centuries has demonstrated that the development of a special legal order of tax avoidance relations had never been raised during that period. At the same time, when discussing the  nature of such relations, researchers made particular conclusions that would be later used to develop the tax avoidance concept. Based on the analysis of particular theses discussed by financial law researchers, the author of the article makes and discusses general provisions of the tax shifting concept and the grounds for the creation of the tax avoidance concept typical for the XIXth - XXth century period.