INTERNATIONAL TAXATION OF INCOME IN RUSSIA: BALKAN PERSPECTIVE

Abstract

This is a study of the current legal framework of international taxation of income between Russia and the Balkan states – Albania, Bosnia and Herzegovina, Bulgaria, Croatia, Greece, Kosovo, Montenegro, North Macedonia, Romania, Serbia, Slovenia. The author analyses existing tax treaty provisions, both bilateral and multilateral, with focus on three main issues – elimination of international juridical double taxation, international administrative cooperation in tax matters and counteraction to tax avoidance and evasion. For the elimination of international juridical double taxation, the comparative research covers tie-breaker rules, distribute rules and methods for the elimination of double taxation as set in the related double tax treaties. The author identifies similarities and differences in the mechanisms used in relations between Russia and the Balkan states. The analysis of the bilateral and multilateral framework for administrative cooperation in tax matters leads to the conclusion that the exchange of information remains the main form of administrative assistance, with application of other forms being limited due to numerous reservations of the states. The exiting regulation of the counteraction to tax avoidance and evasion does not meet the modern standards and provides for a limited scope of special anti-avoidance rules. Six agreements between Russia and the Balkan states are covered by the OECD Multilateral Instrument and the update of the regulation on counteraction to tax avoidance and evasion is foreseeable.