Special Anti-Evasion Rules in International Taxation: The Legal Nature and Developement Prospects

The paper examines the development of special anti-avoidance rules in international taxation: transfer pricing, thin capitalization, taxation of controlled foreign companies and the concept of beneficial right on income. It has been established that the further development of these rules faces serious problems. To solve these problems, it is proposed to recognize that in general, special anti-avoidance rules of international taxation solve problems related to the legal fragmentation of cross-border companies. Recognition of the unity of a group of such companies in tax relations will significantly reduce the need for the application of special anti-avoidance rules.