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Some Issues of Application of Beneficial Ownership Concept
[Некоторые Вопросы Применения Концепции Фактического Права На Доход]

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  • Machehin, Victor (Мачехин, Виктор)

    (The Russian Presidential Academy of National Economy and Public Administration)

Abstract

The concept of the beneficial ownership on income is one of the most demanded in the practice of international taxation. This concept is one of the most controversial and does not have a common understanding among tax authorities and taxpayers, which leads to numerous tax disputes, including judicial ones. Understanding the nature of this concept is extremely relevant in the context of the sanctions pressure exerted on Russia. The development of theoretical and practical approaches to the nature of the concept of the beneficial ownership on income refers to the purpose of the work, the achievement of which was connected with the solution of a number of tasks, namely: to systematize existing views on beneficial ownership on income, to identify the logic of the emergence and development of the concept of beneficial ownership on income. The recommendations are aimed at improving the working conditions of tax authorities and taxpayers applying the concept of beneficial ownership.

Suggested Citation

  • Machehin, Victor (Мачехин, Виктор), 2023. "Some Issues of Application of Beneficial Ownership Concept [Некоторые Вопросы Применения Концепции Фактического Права На Доход]," Working Papers w202347, Russian Presidential Academy of National Economy and Public Administration.
    • Handle: RePEc:rnp:wpaper:w202347
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