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 her article Tsagan-Mandjieva analyzes applicable alternative approaches to direct and indirect taxatin of operations performed to create and transfer cryptocurrency taking into account their decentralized nature. Based on the approaches described, the author of the article summarizes foreign experience in tax regulation of cryptocurrency and defines tendencies in the development of the favorable regulatory environment from the point of view of VAT taxation. Taking into account the offshore nature of cryptocurrency systems Tsagan-Mandjieva makes a conclusion that it is possible to recognize taxable assets only if the virtual currency is converted into fiat currency. In the course of processing information the author has used general research methods such as analysis, synthesis, induction, deduction as well as methods of grouping, comparison, and tabular presentation of data. The novelty of the research is caused by the following: 1) the author describes three approaches to taxation of operations performed to create cryptocurrency (in a manner similar to creation of intellectual property assets (digital goods), extraction of precious metals, obtaining compensation for services rendered) and analyzes drawbacks and advantages of each of them; 2) based on these approaches to recognizing operations performed to create cryptocurrency, the author defines taxable assets developed during operations related to cryptocurrency conversion; 3) the author summarizes positions of the foreign states in accordance with the classification of approaches offered. 
 

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.