Налогообложение Контролируемых Иностранных Компаний По Законодательству Германии И России

The author deals with the topic of tax avoidance by shifting profits to controlling companies in offshore jurisdictions. The goals of Russian and other foreign companies and their controlling shareholders can be very different: protection of property, concealment of ownership structures, tax avoidance, etc. In addition to the economic relevance of the shift in profits, the author deals with the legal regulations and their meaningfulness. Relevant OECD recommendations and the EU Anti-Tax Avoidance Directive are dealt with, including compliance with these recommendations/harmonization rules in Germany and Russia and the need for changes of legislation in both countries.