Organization of activities in low-tax jurisdictions in Russian practice: controlled foreign companies and residence in special administrative regions

The article is devoted to the issues of organization of activities in low-tax jurisdictions in the Russian tax practice. Under the conditions of constantly changing tax legislation of the Russian Federation in the field of preferential taxation there is a necessity of its detailed analysis in terms of existing restrictions and tax benefits provided to Russian companies. The article discusses in a comparative perspective two ways of organizing activities in low-tax jurisdictions, whose regulation is enshrined in the Russian tax code: controlled foreign companies (CFC) and residence in special administrative regions (SAR). The comparative characteristics presented by the author allow to determine the attractiveness and feasibility of using each of the regimes by Russian companies.