Taxes and Taxation
Reference:
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Problem of direct taxation of international agreements on avoiding the double taxation
// Taxes and Taxation.
2008. № 11.
URL: https://en.nbpublish.com/library_read_article.php?id=56079
. Problem of direct taxation of international agreements on avoiding the double taxation
Abstract:
One of the key problems of international legal regulation in the sphere of avoiding double taxation is the various correlation of norms of international and national law in every particular state. The author of this article concludes, that Russia is one of the countries, where the concept of correlation is monist, and provides for priority of international law over national normative legal acts.
In fact, however, the provisions of legislation of the Russian Federation, namely the Tax Code of the Russian Federation, have the priority over the Constitution of the Russian Federation, that is why Russia has some problems related to application of normative legal acts of supreme legal power.
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