Analysis of foreign practice of tax incentives for the development of high-tech industry

Razu Semen Borisovich ORCID: 0000-0003-2554-9609 Postgraduate student; Department of Taxes and Tax Administration; Financial University under the Government of the Russian Federation 129515, Russia, Moscow, Akademika Koroleva str., 9 building 1 semen.razu@mail.ru

Introduction

Currently, the development of high-tech industrial production is one of the key areas of the economy of the leading countries of the world. The creation of new enterprises has allowed individual states to take leading positions in this industry. Thus, China, thanks to significant investments from outside and its own efforts, was able to take a dominant position in the global hi-tech industry. Nevertheless, developed countries still largely retain key positions in this sector due to well-thought-out government policies, including stimulating industry, increasing productivity and updating fixed assets. Fiscal policy plays a key role in this regard, which serves as an effective tool for regulating the development of the national economy. Improving the national tax policy in the field of production development allows us to solve a wide range of tasks, such as achieving technological leadership, ensuring sustainable economic growth and technological sovereignty. Under the conditions of sanctions pressure, Russia is facing the challenges of import substitution and the development of its own production, especially in the field of high technology, which requires significant investments in R&D. In this regard, it seems relevant to study the positive experience of developed industrial countries, which can be used by our country to solve the tasks outlined above. The scientific novelty of the study consists in systematizing the mechanisms of tax incentives for high-tech industry in industrialized countries, highlighting general trends in the development of such mechanisms, as well as justifying the expediency of using their experience in the Russian Federation, highlighting specific mechanisms proposed for borrowing and implementation into Russian practice at the same time. The study also assessed the expected economic effect of these measures and identified specific sectors of the high-tech industry in which it is most appropriate to implement the proposed tax incentive measures. In addition, the scientific novelty consists in making proposals for the adaptation and modification of these mechanisms, taking into account the specifics of the current socio-economic situation in Russia, based on the results of a comparative analysis of indicators of the development of the national economy of Russia and foreign countries using economic and mathematical methods. The object of the study is the tax policy of these countries aimed at stimulating the development of high-tech production and achieving and retaining technological leadership and sovereignty. The subject of the study is specific measures in the field of tax regulation of high-tech industry by the leading industrial powers of the world. The purpose of the work is to study the application of fiscal instruments to regulate the high-tech industry sector of leading industrial countries and the areas of their use, considering their evolution and development. The objectives of the study are as follows:                                                            

1. To analyze the Russian experience of tax incentives for enterprises in the high-tech industry, considering its current state and disadvantages in comparison with other industrialized countries.   

2. Get acquainted with the publications of Russian and foreign researchers in the field of state incentives for the development of high-tech industry, comparing different opinions and approaches on this issue.

3. To study the experience of tax incentives in the high-tech industry by the world's leading industrial companies, identifying common features and trends.

4. Propose measures to improve tax incentives for the Russian high-tech industry based on relevant foreign experience.

Analysis of the experience of tax incentives for high-tech industry in the Russian Federation

To date, much has already been done in relation to tax incentives for industry in the Russian Federation. Among the most significant tax measures, both direct and indirect ones can be distinguished. Direct measures include the following:

• VAT exemption for R&D.
• VAT exemption for the purchase of materials for research and development.
• Tax benefits for SEZ residents (including those of a technical and innovation type) and innovation centers at both the federal, regional and local levels.
• The possibility of accounting for R&D expenses for income tax purposes, regardless of the effectiveness of the result obtained.
• The use of increasing coefficients when accounting for R&D expenses in the tax base.
• The use of accelerated depreciation.
• The availability of tax benefits in relation to the development and implementation of high technologies for users of the simplified taxation system. 

The most significant indirect measures of tax incentives for the development of high technologies in the Russian Federation include the following:

• Application of investment tax deductions.
• The use of depreciation premiums and deferrals for the transfer of taxes to the budget.
• Investment tax credit.
•  Benefits for participants in regional investment projects, special investment contracts, and priority development territories. 

      Despite the rather wide range of tax preferences available to Russian high-tech enterprises, there are still a number of serious problems in the tax regulation of this industry, the main ones of which a number of authors, including D.A. Dubkov, note the following: 

• The low prevalence and demand for the use by organizations of tax instruments provided for by Russian legislation.
• The focus of tax benefits is more on R&D and its binding to the volume of expenses, rather than on results.
• Lack of support for cooperation between manufacturers of high-tech products with research institutes and investment funds in terms of tax benefits for all participants ^{[1, pp. 185-192]}. 

         The low efficiency and demand for tax benefits are also evidenced by the data of a 2017 study by the Higher School of Economics. Thus, according to the university's estimates, among Russian innovative enterprises eligible for benefits, only 14% have benefited from government support. At the same time, only 14.3% of innovative enterprises and only 3% of non-innovative ones directly used tax preferences for accounting for R&D expenses ^{[2, 4 p.]}. Compared with other large economies, Russia is also characterized by a fairly low level of costs for technological innovations, which include both research and development of new products and methods production, as well as for the purchase and commissioning of equipment related to technological innovations. In terms of the ratio of costs for such innovations to GDP, our country ranks only 34th in the world, more than 3 times behind leaders such as Israel or Switzerland. Moreover, according to the HSE in 2018, spending on technological innovations in industry was only 5-7% funded by the state, whereas more than half of the costs were carried out at the expense of companies' own funds ^{[3, 328 p.]}. At the same time, Russia is still among the world leaders in terms of the number of researchers and researchers, which indicates insufficient funding for scientific research ^{[4, pp. 15-17]}. In addition, as noted in a more recent HSE 2020 study, tax incentives account for less than a quarter of the structure of government spending on technological innovations in Russia, whereas most A part is accounted for by direct financing (Fig. 1).

Figure 1. Structure of government spending on technological innovations in 2020, % of GDP

(ISIEZ. Effects of tax incentives for research and development [Electronic resource]. – Access mode: https://issek.hse.ru/news/915110402.html – (Date of application: 04/15/2024).

The low efficiency of Russia's tax policy towards industrial organizations can be considered one of the reasons that, despite numerous attempts by the government since 2014 to reorient the Russian economy towards import substitution and the development of its own technologies, as well as the desire for export diversification, which were indicated in official documents, did not lead to the expected result. Compared with the leading industrial powers, Russia is still characterized by an extremely low level of innovation activity. To date, this indicator in our country is one of the worst among European countries ^{[5, pp. 531-534]}, and over the past 15 years, despite all the efforts of the authorities, this indicator has grown from less than 10% to only 14.6% ^{[6, 292 p.]}. The above factors make it urgent to find ways to improve tax regulation of high-tech industry to reduce the gap from the leading countries of the world.

Literature review

The issues of tax incentives for the high-tech industry have been worrying the minds of many domestic and foreign experts for decades. The main issue that researchers pay attention to concerns the very effectiveness of the application of tax incentives by enterprises of the high-tech industry.

Speaking of foreign scientists, it is worth noting the study by Syum Negassi and Jean-Francois Satten, which concluded that investment tax credits have a significant positive effect on R&D expenses ^{[7, pp. 1-29]}.

A study by Fulvio Castellacci and Christine Mi Lee is also interesting, in which the positive impact of tax credits on R&D spending was also shown using the regression analysis method. At the same time, the authors noted that the greatest effect of tax incentives is achieved in small service enterprises located in underdeveloped countries ^{[8, pp. 819-832]}.

At the same time, the works of other foreign authors contain opposite conclusions. In particular, a study by Luis Alberto Andres, Paulo Correa and Christian Borja-Vega, in which 37 publications were analyzed, indicates a greater effectiveness of direct state support measures compared to tax incentives ^{[9, 56 p.]}. At the same time, Christos Dimos and Kristin Mi Lee in their study claim the absolute inefficiency of state support for R&D. The Russian author Yu.V. Simachev partially agrees with them, who in his publication points to a much smaller effect of tax incentives compared to financial support measures ^{[10, pp. 59-93]}.

According to the author, despite numerous empirical facts indicating the greater effectiveness of measures of direct financing of innovations in industry compared with tax incentives, it is not possible to speak unequivocally about this. In particular, in their work, A. L. Suslina and R. S. Leukhin point out the following undeniable advantages of tax incentives for high-tech industry:  

• Accessibility for a wider range of companies, including small ones.
• A lower degree of state intervention in economic processes.
• Lower level of corruption.
• Transparency and flexibility of the mechanisms for granting benefits.
• Greater freedom of private companies in choosing investment strategies and investment facilities.
•  The absence of displacement of private capital by the state in the high-tech market. ^{[11, pp. 58-69]}

Thus, based on the results of the literature review, it can be concluded that despite the differences between domestic and foreign experts regarding the effectiveness of tax incentive methods for the high-tech industry, it is not possible to talk about their uselessness. In this regard, in order to maximize the effectiveness of the application of tax benefits, it is necessary to identify the most effective of them and suitable for our country in the current conditions, as well as the industries most in need of such benefits. At the same time, in order to supplement the conclusions of experts with new scientific knowledge, it is worth finding out how these tools can be modified and adapted to the realities of the Russian economy.

Analysis of the experience of tax incentives for high-tech industry in the People's Republic of China

In recent decades, experts from all over the world have been paying close attention to China's economic achievements. Until a few decades ago, this country was an agrarian state with a planned economy, the standard of living of the population of which was extremely low. However, under the leadership of Deng Xiaoping, large-scale economic transformations began in the late 1970s: private entrepreneurship became legal, foreign companies gained access to the domestic market, and citizens were granted unprecedented rights and freedoms ^{[12, pp. 154-160]}.

Over the past decades, the Chinese economy has shown impressive growth thanks to the reforms carried out. According to the World Bank, China occupies a leading position in the world in terms of absolute GDP growth over the past 30 years, as well as in terms of GDP at purchasing power parity (Fig. 2). In addition, since the beginning of reforms, there has not been a single year when the Chinese economy has experienced a recession 

Fig. 2. Dynamics of GDP by PPP in current prices across the world, billion US dollars

(The World Bank. GDP, PPP (current international $) [Electronic resource]. – Access mode: https://data.worldbank.org/indicator/NY.GDP.MKTP.PP.CD ?end=2021&name_desc=true&start=1990&view=chart – (Accessed 05.03.2024).

In the field of industrial production, China has been holding a leading position for a long time. Data from the Organization for Economic Cooperation and Development show that before the outbreak of the pandemic, China's share in global industrial production was 35%, which is almost three times higher than the United States (Richard Baldwin, "China Is the World's Sole Manufacturing Superpower: A Line Sketch of the Rise," CEPR, January 17, 2024 [Electronic resource]. – Access mode: https://cepr.org/voxeu/columns/china-worlds-sole-manufacturing-superpower-line-sketch-rise – (Date of application: 03/07/2024).

A feature of China's economic policy is the fact that the country's industrial production is under strict state control, which ensures equal conditions for private companies. Despite the liberalization of the economy, the Communist Party remains the only significant political force in the country. The government retains control over the most important industrial enterprises and develops five-year plans for the national economy.

For this reason, numerous tax incentives for various sectors of the economy are provided in China to encourage the development of innovations. Organizations must meet certain criteria to be eligible for these benefits. Special attention is paid to the reduced income tax rate for companies in high-tech sectors. The standard rate is 25%, but for such companies a rate of 15% or even 10% may be set in some cases (Table 1).

Table 1 – Corporate Income tax in China (Peoples Republic of China: Tax on Corporate Income. PWC. [electronic resource]. – Access mode: https://taxsummaries.pwc.com/peoples-republic-of-china/corporate/taxes-on-corporate-income – (Date of application: 03/07/2024). 

Tax preferences are another key element in stimulating the innovation activities of Chinese companies, surpassing direct subsidies or grants for the introduction of high-tech solutions in this regard.

For China's successful development, it was necessary from the very beginning to attract foreign capital and technology. This was made possible by the creation of special economic zones with little government regulation and soft taxation. Currently, there are more than two hundred such zones in the country ^{[13, pp. 80-93]}.

Convenient conditions have been created for foreign companies that seek to expand their activities in these zones. So, in the most famous FEZ in China – the city of Shenzhen, where, according to various estimates, up to 90% of the world's consumer electronics are produced (5 Things to Know About Doing Business in Shenzhen. [electronic resource]. – Access mode: https://www.inc.com/will-yakowicz/shenzhen-city-of-electronics.html - (Date of application: 03/10/2024), for the first five years after registration, foreign companies are exempt from paying income tax, as well as from most regulatory requirements in force in the main territory of the country.

From attracting foreign technologies to the country, the Chinese government is gradually moving to stimulate the development, implementation and distribution of domestic innovative products and technological solutions to foreign markets. To this end, a reduced tax rate of 12.5% is provided for companies engaged in technology transfer abroad, as well as a full exemption from tax on transfer income in the part not exceeding 5 million yuan.

Tax holidays are another means aimed at stimulating innovation in industry, allowing companies to be exempt from paying income tax for a certain period of time. The conditions for granting such holidays, as well as reduced tax rates, depend on the type of activity of the company (Table 1). Special attention is paid to enterprises engaged in new technologies and servicing advanced production facilities. In China, such enterprises must meet certain criteria.

In addition to the benefits already mentioned, it is possible to use increasing coefficients to deduct R&D costs, which amount to 150% (175% for small innovative organizations).

In conclusion, it is necessary to note four main directions that currently prevail in the strategy of China's tax policy in relation to the industrial sector:

1. Simplification of the procedure for obtaining tax preferences for industrial enterprises.

2. Expanding the list of preferences provided to innovative enterprises, including small ones.

3. The growth of the number and variety of SEZs.

4.                Increasing the reporting requirements of companies.

In general, these trends indicate the desire of the Chinese government to deepen and expand tax incentives for high-tech industrial companies, which has proven its effectiveness in practice. At the same time, the authorities are taking steps to tighten control and improve the effectiveness of regulatory measures, as well as to fine-tune local tax legislation to support the most promising industries in order to make sure that preferences are used only by companies from strictly defined sectors that the government currently considers the most important.

Analysis of the experience of tax incentives for the high-tech industry in the United States of America

Despite the growth of China's economic power, the United States still retains its leading role as a leading industrial power. It is important to note that in modern realities, according to the US Federal Bureau of Labor Statistics, more than 80% of the country's economy is in the service sector, while industry accounts for less than 20% of GDP (Fig. 3). 

Fig. 3. The structure of US GDP in 2022

("Employment by major industry sector". Bureau of Labor Statistics. [electronic resource]. – Access mode: https://www.bls.gov/emp/tables/employment-by-major-industry-sector.htm – (Date of application: 03/10/2024)

Nevertheless, the United States was able to gain its current dominant position in the global economy precisely in the years of its formation as a leading industrial power, starting from the time of the second Industrial Revolution.

In the 1950s, with the beginning of the third industrial Revolution, the United States became the main economic, military, industrial and technological player on the world stage. After the end of World War II and the beginning of the Cold War, huge government investments were needed to develop advanced technologies in the aerospace, nuclear, computer and telecommunications fields. The developments and inventions made in the post-war years are still the basis of the scientific and technical power of developed countries.

Despite the fact that the United States economy has always been characterized by a low degree of government intervention in the economy, the development of complex high-tech technologies and the establishment of mass production of high-tech products would have been impossible without measures of state support for enterprises, including in the tax sphere.

In particular, since the middle of the last century, American tax legislation has allowed enterprises to deduct R&D expenses from the income tax base and amortize them over five years. There were also various tax incentives for scientific research with high social significance, which contributed to the introduction of innovations in key areas of public life.

In the first half of the 1960s, reforms were carried out in the United States, which led to a significant acceleration in the pace of scientific and technological progress. The main changes related to depreciation policy, tax discounts on investments and income tax cuts. These measures have led to a reduction in the service life of fixed assets in key industries, including the chemical industry, metallurgy and rail transport. Companies were given the right to deduct up to 7% of equipment costs from the tax amount. According to the estimates of the US Congress, by the end of the 1960s, this measure allowed American companies to receive benefits worth more than 122 billion US dollars at current prices ^{[14, p. 102]}.

By the early 1980s, the mechanism for deducting R&D expenses had also been significantly improved. Now companies were given the opportunity to deduct up to 20% of expenses that are carried out with the participation of academic institutions. Similar to China, modern tax law reforms in the United States are aimed at creating more targeted and specialized tax incentives to stimulate industrial development, ensuring their targeted impact on the country's key industrial sectors.

In 2014, it was clarified that the costs of creating pilot models of new devices and installations are included in R&D expenses recognized for income tax purposes. Since the beginning of 2015, the conditions for recognizing expenses for the creation and improvement of software developed for management accounting purposes have also been clarified ^{[15, pp. 111-120]}.

To date, the main measures of tax incentives for American industry are an investment tax credit, accelerated depreciation of equipment and benefits for the use of foreign sources in relation to R&D expenses. In addition to federal benefits, a large number of preferences are also provided for by the laws of individual states: local governments have significant powers to adopt their own regulations. Thus, in many states, the scope and nature of the benefits provided is determined by the specifics of the local industry. This approach makes production more attractive to less industrialized regions at the expense of funds collected from enterprises in more developed states. The US authorities use this strategy to solve the problem of deindustrialization in former industrial centers such as Michigan, Pennsylvania, Illinois and Duluth, which are located in the so-called "Rust Belt" of America ^{[16, 272 p.]}. In addition, as in China, the United States has its own SEZs for high-tech companies, the most famous of which is the Silicon Valley in California, which houses the head offices of the largest IT companies using reduced income tax rates and insurance premiums (Silicon Valley: Myths and reality [Electronic resource]. – Access mode: https://www.if24.ru/kremnievaya-dolina-mify-i-realnost/#:~:text=%D0%9A%20%D0%BF%D1%80%D0%B8%D0%BC%D0%B5%D1%80%D1%83%2C%20%D1%81%201%20%D1%8F%D0%BD%D0%B2%D0%B0%D1%80%D1%8F,%D1%81%D0%BE%D0%B2%D0%BE%D0%BA%D1%83%D0%BF%D0%BD%D0%BE%D0%BC%20%D1%80%D0%B0%D0%B7%D0%BC%D0%B5%D1%80%D0%B5%207%2C6%25. – (Accessed 03/15/2024).

Analysis of the experience of tax incentives for the high-tech industry in Japan

When analyzing the foreign experience of tax incentives for industry, it is impossible not to mention a country like Japan. In the last century, this country faced serious difficulties after the Second World War, as a result of which it was on the verge of complete socio-economic collapse. Despite this, thanks to its human resources and scientific and technical potential, as well as significant investments from the United States, Japan was able to survive the difficult post-war years and become a world leader in the production of high-quality industrial products. This was largely achieved due to a competent state policy in the field of taxation of the industrial sector, which assumed the introduction of the most innovative tax mechanisms at that time. For example, in the 1960s, for the first time in the world, Japan introduced a tax discount on R&D expenses.

However, in the middle of the last century, the country faced a serious economic crisis, which led to a halt in rapid growth and caused a long stagnation. The consequences of this crisis have still not been overcome in many ways. This circumstance forced the Government to reconsider its tax policy to stimulate industrial development. At the beginning of the new millennium, the provision of tax benefits became more targeted, including the financing of scientific research. Companies had to prove the effectiveness of such research, and even if successful, it became possible to extend the tax benefits only in a reduced amount. It was also possible to deduct up to 30% of R&D expenses made jointly with universities from the tax base. In addition, measures have been taken to support the export of high-tech products abroad to stimulate the domestic industry. Thus, for tax purposes, it became possible to reduce the income base from technology transfer to other countries by 12% ^{[17, pp. 100-106]}.  

Similar to China and the United States, Japan has also begun to establish SEZs and industrial parks on its territory. The state compensates companies registered in the SEZ for up to a third of the costs of NICOR, and also allows you to write off up to 30% of the cost of equipment and 15% of real estate at a time ^{[18, pp. 121-131]}.

Improving tax incentives for high-tech industry in the Russian Federation

Taking into account the above-mentioned mechanisms of tax incentives for high-tech industry in different countries, taking into account the need to ensure Russia's technological sovereignty, it seems reasonable to use the experience of China and Japan to encourage the transfer of domestic technologies abroad, primarily to friendly jurisdictions. Thus, according to Rosstat, the volume of revenues from the export of Russian technologies in 2021 amounted to 4 billion 663 million US dollars (Information on technology exports by regions of the Russian Federation for 2019-2021. (millions of dollars) [Electronic resource]. – Access mode: https://rosstat.gov.ru/storage/mediabank/Export_2019-2021.pdf – (Date of application: 03/15/2024). If it is possible to reduce the tax base from technology transfer abroad by 12%, similar to Japan, the maximum tax savings of high-tech companies in 2021 could be calculated using the formula (1):                                                                                 

Q = 4 662 700 000*c*12%*t                                                               (1)

where:

Q – the amount of tax savings, rub.;

c is the weighted average exchange rate of the US dollar against the ruble for 2021.

t is the income tax rate, %.

By adopting a tax rate of a base value of 20% and a weighted average exchange rate of 73 rubles 68 kopecks according to the Bank of Russia (Dynamics of the US dollar and euro against the ruble and exchange trading indicators [Electronic resource]. – Access mode: https://www.cbr.ru/hd_base/micex_doc / – (Date of reference: 03/20/2024) and substituting the values in formula (1), you can get the result of calculations in formula (2):

Q = 4 662 700 000*73,68*12%*20% = 8 245 145 664 rub (2) 

Thus, if there is a technology transfer benefit similar to that available in Japan, Russian companies in 2021 could receive a total benefit exceeding 8 billion rubles.

Discussion of the research results

As a result of the analysis, it is possible to systematize various tax mechanisms used to stimulate the high-tech industry in different countries (Table 2).

Table 2 – Availability of tax instruments to stimulate high-tech industry by country. (Worldwide Tax Summaries Online - PwC. [electronic resource]. – Access mode: https://taxsummaries.pwc.com / – (Date of access: 05/27/2024).

As can be concluded from this table, among the main tax mechanisms for stimulating the hi-tech industry in our country, there are only benefits for technology transfer abroad and joint research with scientific institutions. In this regard, according to the author, it is the introduction of these types of benefits that can contribute to the improvement of the state tax policy for the development of industry, increasing the competitiveness and innovative activity of domestic enterprises. Nevertheless, in order to adapt these tools to domestic realities, their refinement is necessary.

As mentioned earlier, when setting the tax deduction at 12% for technology transfers abroad, similar to Japan, the tax savings of Russian companies in 2021 could amount to more than 8 billion rubles. Despite the significant economic effect of this measure at first glance, its relative value compared to domestic R&D costs in the Russian Federation is very small. Thus, according to the Higher School of Economics, in 2021, the internal costs of research and development, taking into account the purchasing power parity of national currencies in Russia amounted to 47.6 billion US dollars, whereas in Japan – 171.1 billion US dollars (Russian Science in 2021 – [Electronic resource]. – Access mode: https://issek.hse.ru/news/759541996.html#:~:text=%D0%9B%D0%B8%D0%B4%D0%B5%D1%80%D0%B0%D0%BC%D0%B8%20%D1%8F%D0%B2%D0%BB%D1%8F%D1%8E%D1%82%D1%81%D1%8F%20%D0%98%D0%B7%D1%80%D0%B0%D0%B8%D0%BB%D1%8C%20(5%2C44,(14%2D%D0%B5%20%D0%BC%D0%B5%D1%81%D1%82%D0%BE). – (Accessed 05/27/2024). Japan exported technologies worth 3,620 billion yen in 2021 (Exports value of technology trade by business enterprises in Japan from fiscal year 2012 to 2021 [Electronic resource]. – Access mode: https://www.statista.com/statistics/613925/japan-technology-trade-export-value / – (Date of circulation: 05/27/2024), which, with the average annual exchange rate of the ruble to the yen in 2021 equal to 1.49 Japanese yen per Russian ruble (Dynamics of the official exchange rate of a given currency [Electronic resource]. – Access mode: https://www.cbr.ru/currency_base/dynamics /?UniDbQuery.Posted=True&UniDbQuery.so=1&UniDbQuery.mode=1&UniDbQuery.date_req1=&UniDbQuery.date_req2=&UniDbQuery.VAL_NM_RQ=R01820&UniDbQuery.From=01.01.2021&UniDbQuery.To=12/31/2021 – (Date of issue: 05/27/2024), is the dollar amount calculated by the formula (3):

Q = 3,620/1,49/73,68 = 32.974 billion US dollars (3)

Thus, the amount of tax savings from the use of technology transfer benefits in Russia can be calculated as a percentage of total R&D expenditures according to the formula (4):

Q = (8 245 145 664/73,68)/47 600 000 000 = 0,24%                                        (4)

A similar calculation can be made for Japan. With a standard general income tax rate of 33% (Taxes on corporate income - Japan – [Electronic resource]. – Access mode: https://taxsummaries.pwc.com/japan/corporate/taxes-on-corporate-income ). – (Date of application: 05/27/2024), the amount of tax savings from the use of technology transfer benefits abroad as a percentage of R&D expenses can be calculated using the formula (5):

Q = 32,974*12%*33%/171,1 = 0,76%                                                    (5)

As a result, it can be concluded that, in relative terms, the economic effect of the introduction of technology transfer benefits abroad in Russia on the same terms as in Japan will be 3 times lower compared to the volume of R&D expenditures produced in the country.  Moreover, unlike Japan, our country is under sanctions pressure from developed industrial powers, which requires decisive measures to stimulate the development of its own hi-tech industry in order to ensure the technological sovereignty of the country. In view of the above, it seems reasonable to set the amount of the benefit at the level of 35% rather than 12%, as in Japan, in order to achieve a similar economic effect. The effectiveness of the introduction of this benefit is also due to its focus not on stimulating R&D spending, but on the actual results of the development of high technologies, which in the future can make it an important element of the Russian tax system due to the small number of such benefits, as previously mentioned in this article.

The next step towards the introduction of benefits should be the identification of the most promising high-tech industries, which should become a priority object of government incentives. According to the research by N. M. Abdikeev, the companies working in the field of scientific research are characterized by the greatest innovative activity and prospects, and the most promising industries in the greatest need of state stimulation are chemical, optoelectronic and computer production ^{[19, pp. 46-53]}. Given the extreme importance of these areas, at the same time, it should be noted that at the moment the most in-demand Russian technologies in foreign markets, according to a study by Yu. V. Solovyova, are engineering services ^{[20, pp. 46-53]}, accounting for 74% of Russian technological exports, while scientific research accounts for only 11% ^{[21, pp. 27-36]}. Among the most demanded branches of the high-tech industry in Russia in foreign countries, it is also worth highlighting the energy sector. Thus, by the end of the 2010s, Russia controlled 90% of the global market for single-walled carbon tubes and modifiers necessary for the production of solar energy ^{[22, pp. 21-35]}, as well as 67% of the global construction of nuclear power plants, which is in great demand by developing countries that maintain friendly relations with Russia (Rosatom plans to expand the construction of nuclear power plants abroad – [Electronic resource]. – Access mode: https://www.cbr.ru/hd_base/micex_doc / – (Date of access: 03/20/2024).

In this regard, according to the author, when introducing benefits for the transfer of domestic technologies abroad, first of all, they should be made available to engineering companies providing services in such high-tech industries as energy, chemical, optoelectronic industry and computer technology. Acting as the flagships of Russian high-tech exports, these industries in the future can not only strengthen Russia's technological dominance and sovereignty, but also diversify the country's export structure, increasing the resilience of the national economy to external shocks.

In addition, to solve another pressing problem of the lack of benefits for joint development of companies with research centers and foundations, it seems reasonable to borrow the experience of the United States and Japan. In particular, the author proposes to introduce into Russian practice the possibility of deducting expenses for joint research from the tax base. At the same time, the introduction of tax measures similar to Japanese and American ones with the possibility of deducting up to 30% of the costs of joint research does not seem sufficient in our country. In addition to the need to accelerate the development of its own technologies in the face of sanctions pressure, another argument in favor of larger-scale steps in this direction is the fact that Russian legislation already provides for significant deductions in the field of R&D expenses. Thus, in accordance with paragraph 7 of Article 262 of the Tax Code of the Russian Federation, R&D expenses included in the government list can already be deducted from the tax base using an increasing coefficient of 1.5. At the same time, as mentioned above, despite the presence of such preferences, Russia still lags far behind Western countries in terms of innovation activity, which requires the introduction of more targeted and effective measures. In this regard, it is possible to set this coefficient at 2 for R&D carried out by companies in conjunction with research institutes and funds investing in the development of high technologies. The list of such institutions should be developed and officially approved by the Government of the Russian Federation in the future, and these institutions should also have the right to apply this coefficient to R&D expenses. Despite the fact that such a measure may lead to a decrease in tax revenues of the budget, in the long term the economic effect of this benefit can significantly intensify the development of high technologies. This seems to be especially relevant for our country, since since the Soviet era, research institutes and design bureaus have been drivers of domestic scientific and technical development, and over the past decades they have accumulated a significant amount of scientific data and developments that may become in demand from private companies with the necessary financial resources for their development.

Conclusions

Thus, it can be concluded that in industrialized countries, tax policy played a key role in shaping their status as leading industrial powers. Regardless of the time and conditions of their industrial development, Governments have used similar fiscal instruments to promote economic development, such as tax incentives and credits for R&D costs, accelerated depreciation of fixed assets, exemption from property taxes for industrial equipment and buildings, reduced income tax rates, the creation of SEZs and industrial parks.

A global trend in the development of industrial tax regulation since the beginning of this century has been an increase in the specification and target orientation of tax benefits. This is reflected both in the tightening of state control and requirements for recipients of benefits, and in the creation of special tax mechanisms and SEZs focused on specific industries.

According to the author, this trend is not accidental and acts as a reaction to the slowdown in global economic growth and increased competition between developed countries and new industrial powers. The return to stimulating industry in countries such as the United States, Great Britain and Japan indicates an understanding of the need to develop the real sector of the economy and combat deindustrialization and financialization of the national economy.

In view of the above, for our country at this historical stage, the application of foreign practices and their adaptation to local conditions can become an effective way to solve pressing problems. In particular, it seems promising to introduce into the domestic tax legislation benefits in relation to technology transfer abroad and spending on R&D in conjunction with research institutes and investment funds.

The article was prepared based on the results of research carried out at the expense of budgetary funds under the state assignment of the Financial University.