Юридична сутність подвійного оподаткування та податкове резиденство в контексті усунення подвійного оподаткування

The still unprecedented rapid pace of world globalization in the 21st century has caused tectonic shifts in the normal way of life of most modern states. The functioning of transnational corporations is currently determined by the system-forming factors of the world economy, which determine the dynamics and vector of its development. There is a clear interdependence between the state’s place in the world economy and the number of giant companies registered and operating within its tax sovereignty. This became the proper basis for the intensification of the processes of interaction of international economies, in order to increase the efficiency of the activities of legal entities within the limits of different tax jurisdictions. It is tax payments and their effective administration that are factors that depend on the further development and efficiency of the functioning of the world economy, which makes mechanisms for solving problems and eliminating negative phenomena in the field of international taxation vital for the further development of humanity. In this context, double taxation, the occurrence of which sharply reduces the investment attractiveness of individual states and the general desire of legal entities to carry out economic activities, appears to be the most serious challenge facing the field of international taxation, the adequate solution of which depends on its discourse. The fact of the negative impact of excessive tax obstacles on the free development of international investment seems to be objective, while the preconditions for a rapid increase in global commercial activity can be seen if effective means of eliminating double taxation are functioning in the international legal system. This indicates the relevance of the disclosure of the above questions in the research, with the aim of carrying out further research in this area by the scientific environment.