跨境交易税收领域的税收关系特征

Alekseн Aleksandrovich Sorokin
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引用次数: 0

摘要

本文对跨境交易税收领域中税收关系的主体、客体和内容进行了分析,根据分析的结果,得出这些关系具有各自的特殊性,从而确定跨境交易税收领域中税收关系的特征。作者认为,跨境交易税收领域的税收关系有其自身的特殊性,这与外国要素主体构成的复杂性(参与者由不同的司法管辖区连接)和特殊客体(跨境经营)有关,这影响到跨境经营各方在存在特殊权利和义务时所表达的法律关系的内容。目前,两国之间的边界极其模糊。所有这些都导致了国家间现金流的增加,从而导致了俄罗斯和世界范围内跨境交易的增加。跨境关系的税收是一个非常相关的话题,因为一方面,俄罗斯的税收立法应该有助于俄罗斯经济的全球竞争力,另一方面,它应该“保护”相关预算的税收基础。这两个目标有时相互矛盾,这可能导致跨境交易征税程序过于复杂的情况。
本文章由计算机程序翻译,如有差异,请以英文原文为准。
Features of tax relations in the field of taxation of cross-border transactions
The article analyzes the subject, object and content of tax relations in the field of taxation of cross-border transactions, according to the results of the analysis, it is concluded that these relations have their own peculiarity The purpose of the work is to determine the features of tax relations in the field of cross-border transactions. According to the author, tax relations in the field of taxation of cross-border transactions have their own specifics, which is associated with the complication of the subject composition by a foreign element (participants are connected by different jurisdictions) and a special object (cross-border operation), which affects the content of legal relations of persons expressed in the presence of special rights and obligations of the parties to a cross-border operation. At the moment, the borders between the countries are extremely blurred. All this leads to an increase in cash flows between countries, as a result, to an increase in cross-border transactions in Russia and in the world. Taxation of cross-border relations is an extremely relevant topic, since, on the one hand, the tax legislation of Russia should contribute to the global competitiveness of the Russian economy, and on the other hand, it should "protect" the base of tax revenues to the relevant budgets. These two goals sometimes contradict each other, which can lead to a situation of excessive complication of the procedure for taxation of cross-border transactions.
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