Aguzarova L.A., Morgoeva A.Kh. Tax Residence of Legal Entities: the Role and Importance in the Procedure of Deoffshorization of the Russian Economy

Abstract: The subject of the research is the role and importance of the concept of "tax residency of legal entities' in the procedure of deoffshorization of the Russian economy. The relevance of this study is confirmed by one of the main problems of the Russian economies: the Russian business offshore. Many us, the Russian residents, directly or indirectly, is closely affiliated with offshore companies.Special attention is paid to the problem of delimitation of the concepts of "beneficial owner" and "actual recipient of income". The definition of the latter concept creates the basis for its use in anti-monopoly and anti-corruption laws.The authors also devote their attention to the issue of tax evasion through the use of low-tax (offshore) jurisdictions and the plan for combating erosion of the tax base and the profit tax.When writing the article the authors have used such methods as the research method, deductive method, inductive method and comparative method. The main conclusions of the research are the following: tax residence is one of the mechanisms for the implementation of the plan for the deoffshorization of the Russian economy; the concepts of "actual recipient of income" and "beneficial owner" are completely different and used for different purposes, the first concept being the subject of discussion even at the level of the OECD; the Convention on mutual administrative assistance in tax cases that is being prepared for ratification provides for the exchange of tax information, assistance in collection of taxes in the territories of the countries participating in the Convention and conducting simultaneous inspections with participating countries.

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