The article deals with the problems arising in connection with the taxation of the digital economy, using the example of the proposals of the OECD and the EU on the introduction of a tax on digital services, as well as unilateral measures of national states in the area of taxation of the digital economy (on the example of the French digital tax). The main question for the study is whether unilateral measures imposing taxes on digital services represent a suitable solution to the tax problems that arise in connection with digitalization. Based on the analysis of current legislation and jurisprudence, the author concludes that provisions of the Tax Code of the Russian Federation on VAT and income tax do not allow to fully collect taxes on income of corporate groups that use digital business models when providing services related to Russian users. At the same time, Russian organizations that conduct similar activities face full tax burden, which allows us to conclude that Russian companies are discriminated against foreign companies. In this regard, it is advisable to consider the issue of taxation in Russia as the part of the profits extracted by foreign companies in the Russian market.

The paper analyzes ways of the informal economy cutback in the Republic of Uzbekistan, used in the tax sphere. The purpose of the study is to summarize the tax measures to solve this problem. During past few years, there have been taken certain steps in this direction, such as concessions for small businesses in catering, reducing the turnover tax rate in the real estate business, holding large-circulation “check” lotteries with valuable prizes, bringing construction industry workers into the legal field, digitalization of tax administration. According to the authors, the proposed tools correspond both to the practices characteristic of foreign experience and to the conditions peculiarities for making business in Uzbekistan. Also, the authors identified some directions for improving the state tax policy in counteracting the spread of the informal economy: focusing on reducing cash turnover through the use of tax deductions for personal income tax and VAT refunds on purchases; the overall tax culture development; digitalization of the tax reporting procedure; improving a legal status the regulation of the self-employed citizens; initiation of a single tax account mechanism. The scientific novelty lies in the research methodology. Based on a comparative legal analysis, the experience of various countries is used to illustrate the features of tax measures applied in practice to reduce the informal economy. The authors assume the theoretical results of the work will embody in proposals for improving the national tax legislation and will improve the Russian economic and legal doctrine, as well as the level of legal research within the EAEU and the CIS.

Subject. The influence of internationalization of tax law on Russian tax law enforcement in the area of corporate taxation is considered in the article.The purpose of the paper is to analyze influence of internationalization of tax law on Russian tax law enforcement in the area of corporate taxation.Methodology. The author uses methods of theoretical analysis, particularly the theory of integrative legal consciousness, as well as legal methods, including formal legal method and methods of comparative law.Results, scope of application. The development of Russian tax legislation is influenced by acts of international organizations, primarily the Action Plan aimed at combating base erosion and profit shifting (BEPS).Trends of regulation of corporate taxation in relationships with participation of a foreign element are considered in the article. The main issues of realization of norms in the area of corporate direct taxation are brought into light, and namely, taxation of royalties, intra-group expenses, thin capitalization rules and transfer pricing. Tax agreements concluded by the Russian Federation do not contain special rules aimed at combating abuses (in contrast, for example, from European anti-avoidance rules).In recent years Russian tax law introduced institutions that had been established and applied in the tax law of foreign countries. These processes are moving forward and are characterized by frequent changes of legislation, which indicates that the concept of deoffshorization and implementation of the BEPS plan is not always elaborated at the stage of adoption of bills.Conclusions. The author comes to the conclusion that the most relevant and most controversial issues are taxation of payment of royalties, debt financing and intra-group expenses. The practice of applying the CFC rules is just starts forming. In addition, there is a tendency to increase the quality and quantity of information sources used by tax authorities to collect evidence, including the expansion of the practice of information exchange.

Информация о статье Дата поступления-17 апреля 2017 г. Дата принятия в печать-20 апреля 2017 г. Дата онлайн-размещения-20 июня 2017 г. Ключевые слова Налоговое право, налог на доходы физических лиц, резидент, нерезидент, доход В статье рассмотрены проблемы налогообложения физических лиц-нерезидентов в российском налоговом праве. Освещены проблемы реализации принципа запрета дискриминации в российском налоговом праве. Показана важная роль судебной практики в развитии механизмов налогообложения нерезидентов.

The article considers the main directions of harmonization in the area of direct taxation in the Eurasian Economic Union (EAEU). Harmonization of direct taxes in the EAEU does not have such a broad legal basis as harmonization of indirect taxes. At the same time, the necessity of harmonization in the area of direct taxation is due to the need to create equal conditions for the implementation of economic activities and to ensure the functioning of the non-discrimination regime in the member states of the EAEU. The article also examines the actions of the EAEU member states on the implementation of the BEPS Action Plan in the national tax legislation.