Factual Receiver of Profit in International, Foreign and Russian Tax Practice

  • Petr Vishnevskiy HSE University
  • Semyon Yankevich HSE University
DOI: https://doi.org/10.17323/2072-8166.2013.2.85.95
Keywords: International Taxation, double taxation, factual receiver of profit, international bonds, SPV

Abstract

The article deals with the notion factual receiver of profitin international, foreign and Russian practice. The problem of applying this notion is being studied on the case study of the emission of international bonds. The study examines different interpretations of factual receiver of profitin international contracts, national laws and court practice.

Author Biographies

Petr Vishnevskiy, HSE University

Postgraduate Student, Department of International Law, National Research University Higher School of Economics. Address: 20 Myasnitskaya Str., Moscow, 101000, Russian Federation. E-mail: petervishnevskiy@gmail.com

Semyon Yankevich, HSE University

Postgraduate Student, Financial Law Department, National Research University Higher School of Economics. Address: 20 Myasnitskaya Str., Moscow, 101000, Russian Federation. E-mail: semyon.yankevich@gmail.com

Published
2013-02-10
How to Cite
VishnevskiyP., & YankevichS. (2013). Factual Receiver of Profit in International, Foreign and Russian Tax Practice. Law. Journal of the Higher School of Economics, (2), 85-95. https://doi.org/10.17323/2072-8166.2013.2.85.95
Issue
No 2 (2013)
Section
Russian Law: Condition, Perspectives, Commentaries

Copyright (c) 2013 Law Journal of the Higher School of Economics

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