Assessment of Existing Instruments for the Redistribution of Tax Revenues Between States and New Approaches to Solving Issues of Interstate Tax Asymmetry

The subject of the study is the phenomenon of abuse of the provisions of international agreements for the avoidance of double taxation, which is manifested both in the actions of private companies and in government tax policy (harmful tax competition). The purpose of the work is to critically evaluate the Subject-to-Tax Rule (STTR), enshrined in the 2023 Multilateral OECD Convention, as a tool for redistributing states’ tax rights to tax income from their sources. Methods of comparative and institutional analysis, methodological approaches and data from the OECD and the IMF on “phantom investments” are used. The study concluded that traditional anti-tax evasion mechanisms are effective against corporate schemes, but they do not limit government incentives that form a structural interstate tax asymmetry, since STTR, with its narrow scope (excluding dividends and capital gains), low marginal compensatory tax rate and high complexity of tax administration, does not provide a real redistribution of tax revenues. between states. It is proposed to improve the methodological approach in terms of expanding the list of included incomes, raising the threshold rate and creating centralized administrative procedures, as well as adapting the initiative as an independent domestic tool in Russian tax policy.

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