Abstract: The subject of this research is the factors that define the potential increase of tax revenue due to introduction in 2018 of the regime of international holding companies in the two special administrative districts. The goal of this article lies in quantitative assessment of fiscal effect that would take place if the companies of the Russians registered in foreign jurisdictions, popular from the perspective of business structuring, would undergo the procedure of redomiciliation in the special administrative districts. The analysis considers the results of sociological surveys on the readiness of entrepreneurs to bring capital back to Russia. The research methodology is based on systemic approach that allows assessing the impact of a set of various economic factors upon the level of tax revenue, as well as involves the principles of behavioral economics and financial sociology. The conclusion is made that in terms of the rate of return of capital transfer at 6.2%, which corresponds with the average return on capital in the developed countries in 1980-2010, the potential fiscal effect from operation of the special administrative district may be estimated in the range from 17 to 30 billions of rubles. The results may be applies in the course of analysis of the efficiency of special administrative districts and deoffshorization policy overall, as well as future improvement of legislation on the international holding companies.

Abstract: In Latin America at the end of the last century, there was a reduction in the role of income taxes, which led to a distortion of the structure of tax revenues in favor of indirect taxes and an increase in social inequality. Since 2007, reforms have been carried out in a number of countries in the region to return to the progressive taxation of citizens' incomes, thanks to which they managed to increase the share of income taxes in the budget and reverse the upward trend of growing inequality. The author of the article discusses the measures taken in the framework of these reforms, evaluates their results and analyzes the lessons that can be learned from the successful experience of transformations. In her research the author has applied such methods as analysis, synthesis, induction, deduction, also methods of grouping, comparison and tabular presentation of data. It has been established that the positive result of the reforms was expressed in the absolute growth of incomes to the budget of the individual income tax and in the reduction of inequality in the region. The reform was particularly successful in Uruguay: according to its results in the structure of tax revenues, the total share of taxes on goods and services decreased from 70 to 50 percent, the share of income taxes increased from 10 to 35 percent and the Gini coefficient decreased by 2 points.

Abstract: The author focuses on regulation of interest expense deduction for the purpose of calculating corporate tax in the Russian Federation. In her research Tserenova analyzes the rules of acting against thin capitalization recommended by the Organisation for Economic Cooperation and Development as part of the Anti-Base Erosion and Profit Shifting Plan (BEPS). The author provides her own evaluation of the indicators of profit tax optimization by Russian companies using across boundary debt financing as well as the influence of actual court judgements on the nature and dynamics of direct foreign investments. When evaluating the scale of thin capitalization in Russia based on statistical data bout direct foreign investments and court judgements, the author has applied the empirical research methods (comparison and measurement) as well as the theoretical research methods (abstraction, analysis and synthesis, induction and deduction and generalisation) to analyse court judgements and OECD guidelines. The author of the article describes peculiarities of approaches to solving the problem of thin capitalization used in Russian law and court practice compared to OECD guilelines, in particular, the use of balance indicators instead of profit indicators, presumption of non-market loans when violating formal criteria, unclear status of undeductable expenses. As a result, the author offers her own recommendations to improve Russia's thin capitalization rules.