Tax control over the taxation of profits of controlled foreign companies: legal specifics and place in the system of state control

Abstract

The author examines the legal specifics of tax control over the taxation of profits of controlled foreign companies and determines the place of such control in the system of state control. The author examines the relation of tax control with state financial control; specifics of tax audits in the field; the powers of tax authorities to request documents, considering the latest changes in tax legislation. Attention is paid to the legal framework of tax control in this area, the exemption of profits of controlled foreign companies from taxation in Russia and the state of current judicial practice in this area. Both general scientific methods (analysis, synthesis, deduction) and special legal methods (formal legal method, method of legal statistics) were used. The use of a combination of these methods allowed the author to come, in particular, to the following general conclusions: tax control over the taxation of profits of controlled foreign companies is a kind of state financial control; the implementation of this control has its own legal specifics: a desk tax audit can be initiated and carried out without submitting a tax return; the powers of the tax authority in terms of requesting information (documents) have been significantly expanded; it is advisable to provide a specific list of documents (information) confirming grounds for exemption from taxation. The novelty of the research lies in the expansion of theoretical ideas in this sphere and is revealed in the conclusions presented by the author.