Abstract: In this article the authors analyze efficiency of VAT tax rebates for IT companies. In particular, they analyze particular features of rebate application such as the collective influence of the rebate on the taxation system and economnic processes in general, efficiency of the rebate from the point of view of achieving the objectives it is supposed to achieve, and the description of the VAT tax rebate in the Russian Tax Code. The results of the critical analysis demonstrate that the existing mechanism of encouraging innovative activity of IT companies by the means of the VAT tax rebate creates numerous effects that interfere with the economic solutions and tax system, the description of the tax rebate is far from being perfect and this creates a great number of tax debates about how to apply the VAT tax rebate. The results also show that there is no proof that the application of the VAT tax rebate is efficient. 

Abstract: This article is devoted to the multilateral tax instrument within the BEPS plan and how the entire concept and particular provisions of it are perceived by participating jurisdictions. To achieve the aforesaid goal, the authors of the article analyze provisions of the multilateral tax instrument within the BEPS plan and official sources of foreign competent authorities explaining positions of these countries regarding the multilateral tax instrument within the BEPS plan. The results of the first part of the research demonstrate that the multilateral tax instrument within the BEPS plan is still far from achieving the goals of international 'tax cooperation' and some key countries prefer not to implement certain provisions of the multilateral tax instrument within the BEPS plan in their double tax treaties based on particularities of their own tax policies. The second part of the research is focused on analyzing the role and position of the Russian Federation regarding the multilateral tax instrument within the BEPS plan. Based on the analysis of Russia's laws, other legal sources and the experience of the foreign states analyzed in the first part of the research, the authors underline provisions of the multilateral tax instrument within the BEPS plan that Russia is not ready to implement in double tax treaties yet. In the third part of the research the authors analyze a new double tax treaty between the Russian Federation and Japan that fully comply with Action 15 of the BEPS plan and multilateral instrument within the BEPS plan, however, they underline that it also has the problems described in the second part of the research. In the third part of their research the authors focus on the features of the mutual agreement procedure within the framework of the aforesaid double tax treaty. Based on their analysis, the authors have discovered a pressing need to reform the mutual agreement procedure and offer their recommendations on how to do it.