DOI: 10.7256/2454-065X.2019.3.29138

Abstract: This article is devoted to the general theoretical issues of the fiscal (tax) sovereignty of the state. The authors of the article try to differentiate between the terms 'tax sovereignty' and 'fiscal sovereignty' taking into account positions of the Constitutional Court of the Russian Federation and analysis of law researches on the issues of fiscal (tax) sovereignty. The authors also analyze the correlation of terms of tax sovereignty and tax jurisdiction of the state. The authors pay special attention to the opportunity of limitation of tax sovereignty. The methodological basis of the research includes such general research methods as analysis and synthesis. The authors have also applied special research methods such as formal law, comparative law and historical law methods. The authors' special contribution to the topic is the systematization and generalization of definitions of fiscal (tax) sovereignty that can be found in research literature and practice o fthe Constitutional Court of the Russian Federation. Based on the research results, the authors emphasize the need to differentiate between the terms 'fiscal sovereignty' and 'tax sovereignty'. Concerning differentiation between the definitions of tax sovereignty and tax jurisdiction, the authors conclude the following: the fact that a state is fiscally sovereign is already the ground for the state to perform its tax jurisdiction. Concerning limitation of tax sovereignty, the authors conclude that voluntary limitation of national law standards as a result of tax treaty is not a limitation but manifestation of sovereignty because bilateral tax treaties set forth neither tax nor punishment for violation of tax responsibilities. 

DOI: 10.7256/2454-065X.2019.3.28133

Abstract: In his article Asabin describes the key parameters of interstate agreements of the Federal Republic of Germany that contain provisions that define the system of international tax rules. The key role of such treaties is determined by their fundamental importance for the development of international economic relatins the Federal Republic of Germany is the party of, it is also determined by the priority of such treaties over the provisions of the republic's national law. Combination of tax legal relations that arise as a result of such treaties is the subject of this article. The research methodology includes formal law method that is used to analyze efficient international treaties as well as comparative law method that is used to define similarities and differences in the tax provisions of international treaties of the Federal Republic of Germany. The parameters defined by the author can be used to develop several classifications of efficient treaties for better objective determination of their peculiarities and comparative analysis of their particular provisions. The researcher has also defined particular groups of treaties that contain tax provisions as well as peculiarities, differences and similarities of interstate agreements the Federal Republic of Germany is the party of. 

DOI: 10.7256/2454-065X.2019.3.29556

Abstract: The article is devoted to the tax risk management system applicable in the process of tax management of an enterprise. Valieva offers her own classification of tax risks to be used as the guideline when maintaining efficient work of tax management of a company. Based on her classification of tax risks applicable in tax management, the author also suggests to create a road risk map for purposes of corporative tax management, the map pointing out stages of risk management, relevant evaluation and corrective measures. In the course of writing her article the researcher has used general research methods and statistical research methods, analysis of theoretical and practical material. The main results of the article include creation of the road risk map that will allow to arrange the tax management process and ensure rational distribution and use of resources as well as increase financial sustainability of a company based on optimizatino of tax payments with minimum expense.

DOI: 10.7256/2454-065X.2019.3.29252

Abstract: The article is devoted to the main changes in the law of the Russian Federation regarding cadastral valuation. Those were the changes that resulted in creation of special budgetary institutions to perform state cadastral valuation. Pursuant to amendments to the law, the main regulatory instrument that govern the activity of state budgetary institutions determining the cadastral value of real estate items is the Federal Law No. 237 'State Cadastral Valuation' of July 3, 2016. The authors of the article describe the new rules for state cadastral valuation and determinatino of cadastral value of real estate items in accordance with The State Cadastral Valuation Guidelines (approved by the Decree No. 226 of the Ministry of Economic Development of Russia on May 12, 2017). Special state budgetary institutions determine the cadastral value of newly registered and previously registered real estate items as well as real items which qualitative and/or quantitative parameters have been changed. These institutions also have the function to give explanations regarding the process of cadastral value determination, collection, processing, systematization and accumulation of data about real estate items. 

DOI: 10.7256/2454-065X.2019.3.29280

Abstract: The subject of the research is the judicial doctrines of the good faith concept in the Russian tax law. The author of the article describes the factors that contributed to the creation of such judicial doctrines, discusses the reasonability of the use of the aforesaid concept in law and focuses on the definition of good faith given by law. Kharitonov examines developing judicial doctrines of 'good-fath taxpayer', 'unjustified tax benefit', and 'good-faith tax administration'. The methodological basis of the research includes formal law methods such as analysis, synthesis, and induction. Moreover, the author has used the historical method and systems approach. The main conclusion of the research is that the use of the good faith concept in Russian tax law has created aforesaid three judicial doctrines, one of these doctrines  Unjustified tax benefit, Good-faith taxpayer, Good-faith tax administration, Tax planning, Tax optimization, Tax law, Judicial doctrine, Good faith, Tax evasion, Tax avoidance

DOI: 10.7256/2454-065X.2019.3.29569

Abstract: The subject of the research is the efficiency indicators of interaction between tax authorities and internal affairs bodies of the Russian Federation in the process of tax control, in particular, as part of on-site and desk tax inspections. The aim of this research is to develop an approach to evaluation of mutual activity of supervisory bodies through the analysis of existing methods of tax control evaluation and to create the system of indicators that allow to evaluate the level and quality of mutual work of two bodies. In the course of the research the authors have applied the following research methods: analysis (historical logical, statistical, systems approach), synthesis, deduction, induction, comparison, generalisation, formalisation as well as graphic and table methods of information visualisation. The authors' special contribution to the topic is the development of the sysdtem of indicators that describe interaction between tax authorities and internal affairs bodies as part of tax inspections. The main conclusion of the article is that for complex evaluation of the mechanism of interaction of aforesaid bodies in the process of tax control, it is necessary to apply the approach that is based on calculations of relevant indicators of both efficiency mark and performance evaluation.