Abstract: Countering the practice of conducting business through several companies for obtaining tax benefits, or in other words, the practice of businesses is fragmentation is a relevant problem not only in the Russian Federation, but also foreign countries. Namely in Canada, small business are qualified for reduction in corporate tax – small business deduction (SBD). At the same time, it substantiated the need for the development of special financial-legal means for preventing taxpayers from misusing it. This article examines the Canadian experience of countering business fragmentation, and discusses various legal means implemented by the Canadian legislator. Special attention is given to the analysis of law enforcement practice of these legal means, including introduction of the “deemed association rule” (Paragraph 2.1, Section 256 of the Law “On Income Tax”). Foreign experience pertinent to legal regulation of countering the practice of business fragmentation has not previously become the subject of detailed analysis, which defines the scientific novelty of this article. The conclusion is made that Canada has a separate legal regulation in form of  the general and special rules aimed at prevention of unscrupulous practices of business fragmentation. The Canadian tax authorities may apply certain special norms prior to resorting to broader discretion. Application of the “deemed association rule”  based on determination of the purpose of separate existence of corporations, draws particular attention. The Canadian law enforcement practice developed the approach, according to which the implementation of this rule should be founded on the objective component and documentary evidence.

Abstract: The subject of this research is the question of implementation of temporary measures in case of non-compliance with the decisions of the Dispute Settlement Body of the World Trade Organization. The author analyzes the implementation of temporary measures in the General Agreement on Tariffs and Trade (GATT), explores the order of implementation of temporary measures with regards to the Agreement of rules and procedures regulating the dispute settlement, studies the question of the volume of suspension of concessions as a temporary measure, as well as the possible issues that can emerge at the stage of determination of the volume. The author analyzes the practice of implementation of temporary measures. The scientific novelty lies in detailed consideration of the order of implementation of temporary measures in case of non-compliance with the decision of the Dispute Settlement Body of the World Trade Organization, as well as examination of the corresponding practice of the countries established within the framework of GATT / WTO. The study of this question remains relevant so that Russia can seize an opportunity for protecting its interests to the fullest possible extent in terms of WTO. The following conclusions were made: compensation is not a sufficiently effective temporary measure, therefore, the countries more often refer to suspension of concessions; mechanism for suspending concessions cannot be called perfect, because the developing countries are often not able to implement such measure for protecting their interests, thus it would seem that such mechanism requires reforms (the introduction of interim relief is possible).