Abstract: The article is devoted to the transfer of insurance payment administration to state social extra-budgetary funds of the Russian Federation tax authorities since January 1, 2017. The object of the research is the social relations arising in the process of administration of the Russian Federation budget revenues. The subject of the research is the definition and objectives of administration of these or those payments, purpose and role of provisions regarding insurance payments in the Tax Code of the Russian Federation as well as the transfer of insurance payment administration by tax authorities and historical experience of legal regulation of calculating and collecting mandatory payments into state social extra-budgetary funds of the Russian Federation. For the purposes of the research the author has used the comparative legal method, analysis of legal sources, restrospective analysis, synthesis and generalization of the research results. As the scientific conclusion, the author offers her own definition of administration of insurance payments into state social extra-budgetary funds, describes goals and objectives of the transfer of powers to administer insurance payments by tax authorities, and analyze powers exercised in the process of administration of the Russian Federation revenue budget system, in particular, powers of tax authorities as administrators of insurance payments to social extra-budget funds.

Keywords: budget revenues, Tax Code, tax authorities, unified social tax, Social Insurance Fund, Pension Fund of the Russian Federation, social extra-budgetary funds, state extra-budgetary funds, insurance payments, administration

DOI: 10.7256/2454-065X.2016.11.68356

DOI: 10.7256/2454-065X.2016.11.20832

Abstract: The present article is devoted to the problems of interpreting the international 'against-tax-avoidance' concept of the beneficial owner of income aimed at counteracting illegal implementation of double taxation treaties. In her research Balakina analyzes the definition of the beneficial owner of income fixed in Clause 2 of Article 7 of the Tax Code of the Russian Federation through such definition criterion as a personal right to use and dispose income. Having analyzed approaches described in OECD Commentaries, foreign legal precedents, points of view of foreign and Russian scientists on internatioinal taxation, and written explanations of the Ministry of Finance of Russia, the author comes to the conclusion that the definition criterion of the beneficial owner iof income fixed in Article 7 of the Tax Code of the Russian Federation does not bear any significant meaning and does not clarify the aforesaid concept. On the contrary, it creates pluralism of opinions regarding what the right to use and dispoise income actually means. The methodological basis of the research consists of general and specific scientific methods and techniques such as dialectical, formal logical, comparative, stryctured system approaches, methods of analysis, synthesis and others. Application of the aforesaid methods allows to combine theoretical analysis with solution of practical tasks that are significant for interpreting and implementing the concept of the beneficial owner of income. The main contribution of the author is that she offers her own definition of the beneficial owner of income instead of the definition fixed in Clause 2 of Article 7 of the Tax Code of the Russian Federation and suggests to inclue this definition in Article 3 of the Typical OECD Treaty No. 84 'On Concluding International Treaties on Avoiding Double Taxation and Prevention of Fiscal Evasion' approved by the decree of the Government of the Russian Federation on February 24, 2010.

Keywords: concept definition criterion, obligation to pass income, treaty shopping, economic approach, technical legal approach, right to dispose income, right to use income, Update OECD Commentaries, International Tax treaties, beneficial owner of income

DOI: 10.7256/2454-065X.2016.11.68357

DOI: 10.7256/2454-065X.2016.11.21012

Abstract: The rules for defining the residency determines the scope of the tax jurisdiction of a state and fiscal conditions for foreign and domestic investors and companies. In their research the authors provide an analytical review of foreign states' approaches to defining the residency of individuals and legal entities and danalyze the concept of residency in terms of international tax policy. The authors also make recommendations regarding development the residency concept in the Russian Federation. They study the connection between rules for defining the tax residency, CFC rules, and non-residents' income taxation system in terms of OECD double taxation avoidance, and Russian tax legislation in part of approaches to the definition of residency. The authors make several important conclusions, for example, that developed countries tend to choose the territorial taxation system. The other conclusion is that due to the international tendency towards automatic information exchange between countries, it is advantageous to avoid the status of Russia's residents even though tax rates are rather low in Russia for individuals who are potential residents of countries with lower individual tax rates or no tax rates at all (such as Saudi Arabia or particular offshore jurisdictions) or countries where CFC rules do not apply.

Keywords: deoffshorization, tax competition, global tax system, territorial tax system, tax policy, tax residency, CFC, DTT, OECD Model Convention, PIT

DOI: 10.7256/2454-065X.2016.11.68358

Keywords: deoffshorization, tax competition, global tax system, territorial tax system, tax policy, tax residency, CFC, DTT, OECD Model Convention, PIT

DOI: 10.7256/2454-065X.2016.11.21076

Abstract: The subject of the research is a new scheme for calculating property tax to be applied as a result of Part 32 of the Tax Code of the Russian Federation entering into force. According to the authors, taking into account the fact that the law does not offer a classifier to differentiate residential properties a new tax collection scheme will have the greatest effect on taxation of old fund buildings as well as buildings located in prestigious areas. The latter is due to assessing officers using a comparative approach and a 'typical object' method that do not usually take into account consumer parameters of residency quality, i.e. comfort of a residential property. In this regard, the authors pay special attention to developing a method of referring a residential property to a particular class considering various price factors constituting its cadastral value. The object of the research is the methods and models of defining the cadastral value of residential properties. The methodology of the research involves principles of the systems approach to economic realities, qualimetry methods, methods of evaluating the quality of an urban residential environment and method of forming the integral rating of the major cities of Russia. The main conclusion of the research is that a new property tax must take into account the social component. In the future consumers will be more pragmatic about choosing a residential property and try to keep a relevant tax burden in mind. The scientific novelty of the research is that the authors develop a method for differentiation of residential properties depending in their comfort level whicdh allows to determine the amount of property tax differentiating tax rates according to the consumer quality of an object.

Keywords: price factors, inventory value, classification of objects, comfort levels, differentiation method, properties, differentiation of objects, cadastral value, property tax, mass evaluation of objects

DOI: 10.7256/2454-065X.2016.11.68304

DOI: 10.7256/2454-065X.2016.11.20870

Abstract: The paper deals with the problem of income taxation of a bankruptcy trustee as a subject of professional activity, his right to use the simplified tax system in the process of implementation of the arbitration management. The characteristics of systematic interpretation of norms of tax legislation and insolvency law (for example, rulings of the Supreme Arbitration Court and the Supreme Court of the Russian Federation) have been analysed in this article. At the theoretical level the legal assessment of the basic legal positions which have been developed in the jurisprudence of the Russian courts on the taxation of income of the arbitration manager is given in the article. The main methods used by the author in this study are the method of systematic interpretation of legal norms and comparison. In her research Kiryanova emphasizes the need to harmonize tax legislation andinsolvency laws regarding the status of a bankruptcy trustee for determination of his tax obligations. Based on the conducted research the author suggests to establish a unified position on the question of taxation of income of the bankruptcy trustee at the theoretical level.

Keywords: systemic interpretation, arbitration control, individual, subject of professional activities, taxation of income, simplified taxation system, special tax regimes, bankruptcy trustee, tax certainty principle, entrepreneurial activity

DOI: 10.7256/2454-065X.2016.11.68359

DOI: 10.7256/2454-065X.2016.11.21158

Abstract: The subject of the research is the system of mineral extraction taxation, problems and prospects for its development. At the modern stage relations in the sphere of raw materials and oil and energy resources are growing especially important because they make a significant influence on the economic growth of the state. The author of the present article pays special attention to the state tax policy in the sphere of mineral extraction taxation. The author examines such aspects of the topic as the need to improve efficiency of the mineral extraction taxation system and to encourage measures aimed at restoring mineral resources in particular branches of economy. The research of the practice of collecting mineral extraction tax was based on the use of general research methods (observation, logical analysis, economic analysis, complex analysis and analogy) as well as specific research methods and procedures (comparison and generalization, selection and grouping of data). The author offers recommendations on how to improve the mineral extraction taxation system under modern conditions. The author analyzes the dynamics of tax revenues from mineral extraction taxes into the Russian Federation budget and defines the main factors that influence the collectability of the aforesaid tax. The author's contribution to the topic is her recommendations on how to review the mineral extraction taxation system and distribute mineral extraction revenues between chains of the budgetary system as well as to shift the emphasis to the taxation of rent revenues and implementation of measures aimed at increasing efficiency of tax authorities' supervisory activities, etc. The author's contribution to the research is also her recommendations aimed at developing the rational system of mineral extraction taxation and increasing efficiency under modern Russian conditions.

Keywords: tax load, tax rates, regulation, rent payments, tax system, taxes, budget, oil, gas, control

DOI: 10.7256/2454-065X.2016.11.68360

Keywords: tax load, tax rates, regulation, rent payments, tax system, taxes, budget, oil, gas, control

DOI: 10.7256/2454-065X.2016.11.21131

Abstract: The main purpose of the research is to state the need to improve indicators of tax authorities’ efficiency, and to develop the institution of tax consulting as an important resource for raising the level of voluntariness of tax payments in the Russian Federation. The subject of the research is the combination of theoretical, methodological and practical issues aimed at defining ways to increase efficiency of tax authorities of the Russian Federation. The object of the research is supervisory and educational activities of tax officials as well as methods used to evaluate their efficiency. In the course of their research the authors have applied statistical methods of economic research (generalization, selection, grouping, comparison), methods of expert evaluation and extrapolation, complex approach, logical, structure-functional and systems analysis. The main conclusions of the research is the proof of the need to develop the institution of tax consulting as a factor of growing trust towards tax authorities and increasing the level of voluntariness of fulfillment of tax obligations. The research demonstrates that activities of tax authorities aimed at improving services for taxpayers can serve as an important resource for observing tax discipline. The authors also define the need to legally acknowledge the institution of tax consulting as the main element of the tax administration system. The scientific novelty of the research is caused by the fact that the authors develop a set of scientific and practical recommendations aimed at improving indicators of evaluating the efficiency of tax authorities, developing information services and implementation of the principle of voluntary fulfillment of tax obligations as a target of tax transformations in recent times. The main contribution of the research is the authors’ conclusion that the combination of indicators recommended by the Federal Tax Service of Russia for evaluating the efficiency of tax authorities is difficult to be applied. It does not relate to preventive activities and the principle of voluntary fulfillment of tax obligations and does not consider the risks of non-payment of particular kinds of taxes. This creates the need to improve them. In their article the authors prove the need to provide a clear description of competences of tax authorities at the legal level when the authorities require relevant information in the process of supervisory measures with reference to both the list of competences and implementing procedures.

Keywords: field (onsite) audits, tax control, efficiency evaluation, Federal Tax Service of Russia, parnter model, voluntariness, field (onsite) audits, tax payments, authorities, ion of consulting

DOI: 10.7256/2454-065X.2016.11.68311

Keywords: field (onsite) audits, tax control, efficiency evaluation, Federal Tax Service of Russia, parnter model, voluntariness, field (onsite) audits, tax payments, authorities, ion of consulting

DOI: 10.7256/2454-065X.2016.11.21251

Abstract: The object of the research is the special tax regimes and their role in supporting small business in Russia. The subject of the research is the analysis of the gaps and contradictions in the legislation regulating applicability of special taxation regimes. The article presents the results of analyzing changes in the tax laws regarding small business in Russia and special taxation regimes in particular. The authors of the article make an assumption that the efforts made by the Government of the Russian Federation in order to simplify administration of taxation regimes are necessary but insufficient. Having analyzed the judicial practice and legal provisions regulating the application of special taxation regimes, the authors discover that active actions made by the Russian Federation Government in order to introduce additional tax recessions and preferences for small business will be not have a positive effect unless certain contradictions are eliminated in the Tax Code of the Russian Federation. The methodological basis of the research is the systems analysis of the tax legislation, letters of the Ministry of Finances of Russia and instruction of the Federal Tax Service of Russia that contain contradictions with regard to administration of special taxation regimes. The scientific novelty of the research is caused by the fact that based on the results of the analysis of tax legislation regulating special taxation regimes, the authors make a conclusion that the efforts applied by the government in the sphere of taxation is not efficient enough. To support small business, the government uses a standard set of methods such as reduction of tax rates, expansion of tax preferences, etc. Meanwhile, it is necessary, first of all, to conduct a revision of the applicable tax legislation, in particular, parts of the Tax Code of the Russian Federation regulating implementation of special tax regimes, and to eliminate uncertainties and contradictions that create actual hindrances for the development of small entrepreneurship. For the moment tax laws do not distinguish between small, medium and large business which, according to the authors of the article, is wrong. In case of small business where special taxation regimes are applied, it is necessary to apply the principles of simplicity and easy use of tax laws which implies, first of all, elimination of contradictions and uncertainties. The results of the research can be used in the legislative decision-making process regulating special taxation regimes.

Keywords: tax schemes, shadow economy, principles of taxation, tax disputes, contradictions in legislation, special regimes reform, taxation regimes, small business, tax exemptions, monitoring of tax legislation

DOI: 10.7256/2454-065X.2016.11.68325

DOI: 10.7256/2454-065X.2016.11.21024

Abstract: The subject of the present research article is the peculiarities of the process of providing and exposing financial resources of the municipal governments in Russia, in particular, in the Ufa and Orenburg Governorates during the post-reform period. In his research Ishimbaev offers his classification of budget revenues and expenditures and analyzes the legal mechanism used for preparing and approving the city's budget scheme. The author of the article pays special attention to the analysis of particular results of economic activity in the cities of the Ufa and Orenburg Governorates after the Municipal Statute of 1870 had come into force. The methodological basis of the research involves general research methods such as empirical method, analysis, and specific research methods such as statistical and historical methods. The scientific novelty of the research and rationale of the topic are caused by the fact that the author analyzes the content of the city budget expenditures and analyze the budget policy of municipal governments in major cities and small towns of the Ufa and Orenburg Governorates. The author makes a conclusion that the opportunity to provide public budgets obtained by cities and towns after the Municipal Statute of 1870 had come into force increased the amount of city's budget revenues.

Keywords: municipal reform, activities of local authorities, city's economy, local government, budget expenditures, budget revenues, municipal finance, city budget, municipal tax, economic development

DOI: 10.7256/2454-065X.2016.11.68361