К вопросу о результативности изменения (расторжения) налоговых соглашений с Кипром, Мальтой и Люксембургом (на примере дела «КСА Дойтаг Дриллинг»)
The article is devoted to the theoretical and practical aspects of changing and terminating international tax treaties of the Russian Federation with so called transit jurisdictions (Cyprus, Malta and Luxembourg). The corresponding changes of tax policy in respect to passive income (interest and dividend) were envisaged in the list of assignments given by the President of the Russian Federation as a result of the appeal on the 25th of March 2020 in the context of coronavirus infection outbreak in the country. The author analyses the peculiarities of changes that are to be introduced to the agreement with Cyprus, identifies factors that reduce the effectiveness of higher tax rates. The author makes a conclusion that the goal to defend the national tax base can’t be achieved without the Russian tax legislation improvement, including by means of specification of the term «dividends» for the purposes of income taxation.