Taxes on External Economic Activity and Their Impact on Business Outcomes

It must be admitted that the taxes are an integral part of the State, the objectives and functions of the Institute of the State are unthinkable without them. Despite the variability of priorities of nation-building and views on the essence of Taxes in different historical epochs, the financial and economic foundation of this relationship remains unchanged and consists of the need of withdrawal of a part of the income to the State for the formation of its centralized financial resources. The tax legislation of the Russian Federation since its adoption has undergone major changes in the direction of improvement and harmonization with international principles of taxation. But at the same time the tax law of the Russian Federation, in part of international taxation is still not perfect and requires further development. The present study attempts to define the role of taxes in external economic Activity. Thus, the primary objective of the research is to identify the impact of tax planning on the outcomes of a foreign trade company, as well as search for ways to improve the tax legislation of the Russian Federation.

In contrast to actions of national tax authorities interested in increasing of tax revenues, the economic entities, especially transnational companies, tend to use different ways to minimize their tax burden. In foreign practice tax regulations of transnational companies, as well as foreign trade transactions arose and developed lingeringly and thoroughly. At the same time Russia does not have such a rich experience of management of international taxation. A comprehensive study of foreign practice of international taxation is the key to solving the problem of foreign direct investment. The current interest in the problem lies in the development of tax policy in external economic activity of Russian enterprises. It have a positive impact on the investment potential of Russia. The assumptions and findings of the study can be useful for a variety of purposes whether academic or practical.

The study of the issue of taxation of foreign trade company, as well as research of ways to improve the Russian tax legislation in part of taxation of foreign trade transactions, is based on two basic approaches. The first approach is based on the study of theoretical and methodological foundations of the modern tax planning in the field of foreign trade activities. Its basis became researches of domestic and foreign economists on issues of international economic relations and tax planning, as well as international legal acts and international arbitration practice. The study used techniques of logical and theoretical analysis of new aspects of the use of tax planning in organization of foreign trade and international investment transactions. The second approach is based on econometrics and statistics. It allows assessing levels of tax planning in the modern world economy, to compare and evaluate the competition between offshore zones, and also consider the degree of cooperation in the field of tax cooperation within the EU.

The role and impact of international tax planning on business outcomes are widely discussed in the scientific community. The view that the international tax planning has become an integral part of the global economy and it can not be refused without a major overhaul of the entire economic system prevails in domestic and foreign scientific literature. Also various aspects of taxation optimization schemes are considered and the results of implementation of these schemes are studied, as well as theoretical basis of tax planning. Many consulting agencies, for example, PricewaterhouseCoopers, conduct their own research of this field and publish their reports. The study reflects opinions of well-known Russian specialists in this subject such as Pogorletsky A.I., Polezharov L.V., Fomin O.A., as well as foreign authors, Frankel J., Qureshi A., Channels L., Davies D. and Spitz B. The research is based on statistical data provided by various consulting agencies, as well as the OECD and the IMF.

Theoretical basis for tax planning was considered in the first chapter of the study. The ways of minimization of taxes such as: tax evasion, tax avoidance, tax planning, tax arbitrage, and their fundamental differences were identified. Transfer pricing, intercompany credit, advantages of international tax agreements, Russian and foreign experience for combating violations of tax laws were considered too. In the second chapter various schemes of tax optimization were considered. They all have a number of indisputable advantages, but at the same time are not devoid of weaknesses, which is primarily due to inadequate study of issues of legislative regulation of international double