DOI: 10.7256/2454-065X.2016.8.20225

Abstract:

DOI: 10.7256/2454-065X.2016.8.19315

Abstract: The subject of the present research is the estimation of the criteria defining characteristics of the tax residency of companies. The object of the research is the principles for determining tax residency of companies. The author of the article also underlines that tax residency is one of the fundamental concepts in the construction of the tax system and the common methodological platform for building and formalization of relations of subjects of foreign economic activity with different tax jurisdictions. Thus, the legal regulation is aimed at establishing residency subject composition and status of entities. The guidelines for determining tax residence companies involve (1) the place of incorporation, (2) the center of management and control, (3) the place of management; and (4) the place of effective management. The article describes the features of the principles determining tax residency. The place of incorporation is included as the last criterion for determining tax residency in case of failure of the preceding tests. Using econometric and statistical methods, in his research Grundel analyzes theoretical developments of the current legislation set forth by tax administrations of foreign countries, particularly the establishment of the basic principles of determining the residency of companies. In terms of the manipulation for multinational companies it is difficult to move all the factors influencing the determination of residency jurisdiction in the country with the low tax burden. The author concludes that it is necessary to use the conflict rules for determining the country of residency for physical entities as in the case with legal entities. The provisions set forth by the OECD Model Tax Convention for legal entities should be transferred to the obligation to determine the residency of physical entities. 

Keywords: place of management, place of incorporation, Model Tax Convention, functional analysis, center of vital interests, residency criteria, principles of residency, international taxation, place of effective management, transfer pricing

DOI: 10.7256/2454-065X.2016.8.68021

Abstract: The subject of the research is income tax revenues in the regional budget of the Russian Federation. The authors of the article analyze the possibility of using factor models for predicting tax revenues. The purpose of the research is to connect socio-economic indicators of regions with the volume of receipts of the income tax. To achieve the aforesaid target, it is necessary to allocate the factors defining receipts of income tax in the regional budget and to establish their mathematical dependence with the income tax. In order to achieve the reserach goals, the authors have chosen significant factors, and have constructed one-factor and two-factor mathematical models of receipt of income tax depending on qualititaive elements of the tax. The Nizhny Novgorod Region is chosen as the case study. Based on the analysis of data from the Federal Tax Service of the Russian Federation and Federal State Statistics Service of the Russian Federation the authors have created regression models. As a result of the research the authors have developed one-factor models to demonstrate the relation between the target indicator (the amount of the income tax received by the regional budget) and sign factors. They have also outlined two significant sign factors to be used in the two-factor model that would reflect the influence of indicators of the amount of tax payments on regional tax revenues (in the Nizhny Novgorod Region). To prove the significance and validity of the models the authors have used mathematical and statistical methods. All the models have been recognized as significant based on the research results. The authors of the present research have established the mathematical relationship (in the form of regression models) between income tax revenues and their determinant factors.   

Keywords: number of taxpayers, accounts receivable, correlation, tax income, regional budget, sign factor, regression model, income tax, tax revenue, modeling of the income

DOI: 10.7256/2454-065X.2016.8.19873

Abstract: The subject of the research is income tax revenues in the regional budget of the Russian Federation. The authors of the article analyze the possibility of using factor models for predicting tax revenues. The purpose of the research is to connect socio-economic indicators of regions with the volume of receipts of the income tax. To achieve the aforesaid target, it is necessary to allocate the factors defining receipts of income tax in the regional budget and to establish their mathematical dependence with the income tax. In order to achieve the reserach goals, the authors have chosen significant factors, and have constructed one-factor and two-factor mathematical models of receipt of income tax depending on qualititaive elements of the tax. The Nizhny Novgorod Region is chosen as the case study. Based on the analysis of data from the Federal Tax Service of the Russian Federation and Federal State Statistics Service of the Russian Federation the authors have created regression models. As a result of the research the authors have developed one-factor models to demonstrate the relation between the target indicator (the amount of the income tax received by the regional budget) and sign factors. They have also outlined two significant sign factors to be used in the two-factor model that would reflect the influence of indicators of the amount of tax payments on regional tax revenues (in the Nizhny Novgorod Region). To prove the significance and validity of the models the authors have used mathematical and statistical methods. All the models have been recognized as significant based on the research results. The authors of the present research have established the mathematical relationship (in the form of regression models) between income tax revenues and their determinant factors.   

Keywords: number of taxpayers, accounts receivable, correlation, tax income, regional budget, sign factor, regression model, income tax, tax revenue, modeling of the income

DOI: 10.7256/2454-065X.2016.8.68022

Abstract: The object of the research is the mechanism for collecting individual income tax (personal income tax) and its social role. The subject of the research is the need to increase the social role of the individual income tax (NDFL) in the Russian Federation. Focus is made on evaluating the social orientation of the existing mechanism for calculating and collecting individual income tax in the Russian Federation. Special attention is paid to determining systems problems weakening the social role of personal income tax. The author also conducts a comparative analysis of the experience in calculating individual income tax in industrialized countries and individual income tax in Russia. In the course of the research the author demonstrates that the mechanism used to calculate and collect individual income tax in Russia does not observe the principle of the social orientation of taxes. In her research Musaeva makes an extensive use of graphic calculation instruments as well as  many kinds of research methods including the dialectical approach, methods of systems and comparative analysis and synthesis, statistical selection, grouping and generalization, factor analysis and logical analysis. The scientific nvelty of the research is caused by the fact that the author developes grounded guidelines to increase the social role of individual income tax, to decrease social tension in the society and encourage the growth of labor productivity in the Russian Federation. In order to fully realize the social role of individual income tax, it is necessary to impose the progressive taxation method on excess income and non-labor profits. The author proves the need to provide exempt from taxation of citizens' income necessary to provide life support of taxpayers and their families at the subsistence wage level. The author demonstrates that the factors decreasing the social role of individual income tax in the Russian Federation are the low profits of the majority of population as well as the large amount of 'black' profits. The author emphasizes the need to reform the current system of labor relations, to increase wages in economic sectors which would allow to increase the amounts of individual income tax in the future, to lower the amounts of insurance contributions to state social non-budgetary funds, to transfer part of tax burden from entrepreneurs to physical entities and to perform a number of social reforms. 

Keywords: Russian Federation, earnings, excess profit, mechanism of collection, social deductions, employment relationships, social role, NDFL (PIT), individual income tax, industrialized countries

DOI: 10.7256/2454-065X.2016.8.19986

Abstract: The object of the research is the mechanism for collecting individual income tax (personal income tax) and its social role. The subject of the research is the need to increase the social role of the individual income tax (NDFL) in the Russian Federation. Focus is made on evaluating the social orientation of the existing mechanism for calculating and collecting individual income tax in the Russian Federation. Special attention is paid to determining systems problems weakening the social role of personal income tax. The author also conducts a comparative analysis of the experience in calculating individual income tax in industrialized countries and individual income tax in Russia. In the course of the research the author demonstrates that the mechanism used to calculate and collect individual income tax in Russia does not observe the principle of the social orientation of taxes. In her research Musaeva makes an extensive use of graphic calculation instruments as well as  many kinds of research methods including the dialectical approach, methods of systems and comparative analysis and synthesis, statistical selection, grouping and generalization, factor analysis and logical analysis. The scientific nvelty of the research is caused by the fact that the author developes grounded guidelines to increase the social role of individual income tax, to decrease social tension in the society and encourage the growth of labor productivity in the Russian Federation. In order to fully realize the social role of individual income tax, it is necessary to impose the progressive taxation method on excess income and non-labor profits. The author proves the need to provide exempt from taxation of citizens' income necessary to provide life support of taxpayers and their families at the subsistence wage level. The author demonstrates that the factors decreasing the social role of individual income tax in the Russian Federation are the low profits of the majority of population as well as the large amount of 'black' profits. The author emphasizes the need to reform the current system of labor relations, to increase wages in economic sectors which would allow to increase the amounts of individual income tax in the future, to lower the amounts of insurance contributions to state social non-budgetary funds, to transfer part of tax burden from entrepreneurs to physical entities and to perform a number of social reforms. 

Keywords: Russian Federation, earnings, excess profit, mechanism of collection, social deductions, employment relationships, social role, NDFL (PIT), individual income tax, industrialized countries

DOI: 10.7256/2454-065X.2016.8.68023

Abstract: The object of the present research is the taxation of residential properties. The subject of the research is the price zoning of the city area for evaluating the role of the location of residential properties in the taxable price thereof. The author of the article offers a multi-stage algorithm for converting data on the price of residential properties sourced by the secondary market into a value set of the relative price of the reference object as well as describes opportunities for using this value set in the implementation of the cluster analysis formal procedures and transfer from clusters to price zones. The methodology of the research is based on the cluster sampling of residential properties sold on the secondary market, pattern recognition methods and experience in price zoning. The scientific novelty of the research is caused by the fact that the author develops a new method of price zoning for housing taxation which allows to overcome the problem of heterogeneous initial data (numerous series of apartments, types of houses with household plots, etc.) that distorts clusterization results or even makes them inadequate for practical use. Using the aforesaid method, the author of the article draws out the map of price zoning of Bishkek.   

Keywords: cluster analysis, vector of characteristics, correction value, registration quarter, reference object, value of the property, housing tax, price zoning, residential properties, price zone

DOI: 10.7256/2454-065X.2016.8.19993

Abstract: The object of the present research is the taxation of residential properties. The subject of the research is the price zoning of the city area for evaluating the role of the location of residential properties in the taxable price thereof. The author of the article offers a multi-stage algorithm for converting data on the price of residential properties sourced by the secondary market into a value set of the relative price of the reference object as well as describes opportunities for using this value set in the implementation of the cluster analysis formal procedures and transfer from clusters to price zones. The methodology of the research is based on the cluster sampling of residential properties sold on the secondary market, pattern recognition methods and experience in price zoning. The scientific novelty of the research is caused by the fact that the author develops a new method of price zoning for housing taxation which allows to overcome the problem of heterogeneous initial data (numerous series of apartments, types of houses with household plots, etc.) that distorts clusterization results or even makes them inadequate for practical use. Using the aforesaid method, the author of the article draws out the map of price zoning of Bishkek.   

Keywords: cluster analysis, vector of characteristics, correction value, registration quarter, reference object, value of the property, housing tax, price zoning, residential properties, price zone

DOI: 10.7256/2454-065X.2016.8.68024

Abstract: The subject of the present research article is taxaton of small business enterprises in the Russian Federation. In her research Frumina examines peculiarities of taxation of small business enterprises taking into account the most recent legislative amendments. Much attention is paid to special tax regimes and tax issues faced by small enterprises as a result of their financial and economic activity. The author of the article provides statistical data regarding payments of taxes by small enteprises and considers particular issues of tax regulation as an opportunity to refill the income base of the Russian Federation budget during the period of sequestering. Using the methods of induction, deducation and comparative analysis the author examines advantages and disadvantages of the current system of small business taxation in the Russian Federation. The main conclusions made by the author as a result of her research cover particular provisions related to harmonization of the Russian Federation legislation regulating taxation of small and medium business entities. In particular, the author questions whether it would be reasonable to refuse from the single tax on imputed earnings and impose limitations on the simplified tax system in 2018. 

Keywords: tax regulation, financial regulation, tax law, tax policy, budget, special tax regimes, tax, small business, tax burden, tax benefits

DOI: 10.7256/2454-065X.2016.8.19839

Abstract: The subject of the present research article is taxaton of small business enterprises in the Russian Federation. In her research Frumina examines peculiarities of taxation of small business enterprises taking into account the most recent legislative amendments. Much attention is paid to special tax regimes and tax issues faced by small enterprises as a result of their financial and economic activity. The author of the article provides statistical data regarding payments of taxes by small enteprises and considers particular issues of tax regulation as an opportunity to refill the income base of the Russian Federation budget during the period of sequestering. Using the methods of induction, deducation and comparative analysis the author examines advantages and disadvantages of the current system of small business taxation in the Russian Federation. The main conclusions made by the author as a result of her research cover particular provisions related to harmonization of the Russian Federation legislation regulating taxation of small and medium business entities. In particular, the author questions whether it would be reasonable to refuse from the single tax on imputed earnings and impose limitations on the simplified tax system in 2018. 

Keywords: tax regulation, financial regulation, tax law, tax policy, budget, special tax regimes, tax, small business, tax burden, tax benefits

DOI: 10.7256/2454-065X.2016.8.68025

Abstract:

Keywords: finansovoe regulirovanie, nalogovaya politika, byudzhet, nalog, malyi biznes, nalogovoe regulirovanie, nalogovaya nagruzka

DOI: 10.7256/2454-065X.2016.8.20325

Abstract: The subject of the study is the social relations regulated by the legislation on taxes in Inner Mongolia, after Mengjiang state was established in 1937. The author examines the tax instruments, mechanisms of replenishment of the state budget and the measures taken by the relevant public authorities for this purpose in detail, including tax reform and the improvement of the legislative base. The study reveals the types and amounts of taxes, the structure of the tax authorities, shows the features of the tax policy in Mengjiang’s neighboring political formations - Chang'an and Jinbei. The objective is achieved through the analysis of normative legal material, as well as previously unpublished data from the statistical compilations and economic journals. The main conclusions of the study are the significant progress and effectiveness of the chosen methods of the occupying forces, which led to the desired result and ensured the completion of the military budget. The contribution of the author is the structuring of the tax system and the introduction of the new scientific data relating to one of the economically and strategically important regions of China - Inner Mongolia.

Keywords: Legal regulation, taxes, Tax policy, Tax system, Mengjiang, Inner Mongolia, Japanese occupation, Republic of China, Normative legal acts, military budget

DOI: 10.7256/2454-065X.2016.8.67961

Abstract: In her article Zadorozhnaya analyzes guidelines for tax control of transfer pricing in Russia as amended effective of January 1, 2012, from the point of view of their conformity with the principle of the balance of public an dprivate interests. The author analyzes both general conformity of involuntary adjustment of taxable base by tax authorities when rules of tax control over transfer pricing are applied and particular aspects of the subject matter (definition of transaction for the purposes of tax control over transfer pricing as well as competences of tax authorities when checking the calculation and payment of taxes resulting from transactions between related parties). The author has applied theoretical legal approaches to the definition of the 'balance of private and public interests' in relation to effective rules regarding tax control of transfer pricing in Russia. The author has also analyzed judicial and administrative practice on the matter. The main conclusion of the present research is that adjustment of a taxpayerâ' taxable base based on the rules of tax control of transfer pricing does not distort the balance of public and private interests because it does not mean that the taxable base is not created in the place where it has never been before (i.e. during transactions between related parties) but the recorded profit 'hidden' by the other party is 'requalified' as part of the taxable base that has been formed as a result of transaction performed by the party which should have recorded it. These rules are based on the principles of taxation equality, 'substance over form', preservation of an appropriate taxable base and prevention of double taxation, economic justification and fair taxation. At the same time, the author states that there are some guidelines in the Tax Code of the Russian Federation (herein after TC of the RF) that need to be reviewed. Thus, provisions of Clause 11 of Article 105.7 of the TC of the RF significantly decrease the level of certainty and predictability in relations between taxpayers and tax authorities and this is why cannot be considered to be adequately restricting taxpayers' rights. Moreover, the term 'transaction' used in Section V.1 of the TC of the RF is narrow and less accurate than it is needed for the purposes of efficient tax control over transfer pricing which distorts the balance of public and private interests and does not allow to control the relations that should be controled (such as labor relations, debt conversion, etc.) while sets control over the relations which cannot be controled. According to the author, if not limited by the requirements of Section V.1 of the TC of the RF, control of transfer pricing by territorial tax authorities during tax audits creates unequal conditions for taxpayers depending on the type of transaction performed.

Keywords: transfer pricing, the arm’s length principle, balance of interests, Federal Tax Service of Russia, OECD Guidelines, tax audit, territorial tax authority, transaction, adjustment of taxable base, related parties

DOI: 10.7256/2454-065X.2016.8.67963

Abstract: The subject of the present research is the estimation of the criteria defining characteristics of the tax residency of companies. The object of the research is the principles for determining tax residency of companies. The author of the article also underlines that tax residency is one of the fundamental concepts in the construction of the tax system and the common methodological platform for building and formalization of relations of subjects of foreign economic activity with different tax jurisdictions. Thus, the legal regulation is aimed at establishing residency subject composition and status of entities. The guidelines for determining tax residence companies involve (1) the place of incorporation, (2) the center of management and control, (3) the place of management; and (4) the place of effective management. The article describes the features of the principles determining tax residency. The place of incorporation is included as the last criterion for determining tax residency in case of failure of the preceding tests. Using econometric and statistical methods, in his research Grundel analyzes theoretical developments of the current legislation set forth by tax administrations of foreign countries, particularly the establishment of the basic principles of determining the residency of companies. In terms of the manipulation for multinational companies it is difficult to move all the factors influencing the determination of residency jurisdiction in the country with the low tax burden. The author concludes that it is necessary to use the conflict rules for determining the country of residency for physical entities as in the case with legal entities. The provisions set forth by the OECD Model Tax Convention for legal entities should be transferred to the obligation to determine the residency of physical entities. 

Keywords: place of management, place of incorporation, Model Tax Convention, functional analysis, center of vital interests, residency criteria, principles of residency, international taxation, place of effective management, transfer pricing