International conventions on avoidance of double taxation: effectiveness of legal regulation

Unification of national tax systems is an integral sign of globalization of world economy. Contingence of tax systems of different states allows creation a favorable tax climate for investors. Herewith, unification of tax systems should not violate fiscal interests of each state and its national rights. Double taxation is a block for international economical integration and trade. The problem of elimination of double taxation is solved by way of international tax conventions. The majority of conventions on elimination of double taxation reached with participation of the Russian Federation do not limit tax remissions for companies registered in foreign jurisdictions. This stimulates the use of tax remissions in schemes of aggressive minimization of taxation. This article reviews problems of legal regulation of making and realization of international conventions on elimination of double taxation. The article determines basic tax risks connected to evasion of taxes by Russian taxpayers while implementing the conventions on elimination of double taxation.