Subjects of interpretation of agreements on the avoidance of double taxation in the Russian Federation

The interpretation of norms is a key condition for their application in law and allows for a uniform understanding, which is critically important for preventing double taxation and ensuring predictability in law enforcement practice. That is why the subjects of the interpretation of double taxation avoidance agreements in the Russian Federation, as well as the criteria for qualifying interpretation as official or unofficial, are the focus of this study. The classification determines whether the result of the interpretation has binding force. An important aspect of the research is the determination of the consequences arising from official and unofficial interpretations of double taxation avoidance agreements. Questions regarding the legal force of official interpretation, its binding nature for taxpayers and tax authorities, as well as the role of unofficial interpretation in the enforcement process, are analyzed. In writing this article, analytical, deductive, inductive, systemic, and functional research methods were employed. The author provides examples of interpretation of double taxation avoidance agreements by various subjects, including their parties, national courts, tax authorities, and taxpayers. The goal of the article is to identify the subjects whose interpretation of double taxation avoidance agreements will be considered official and have obligatory significance. The author analyzes the significance of the mutual agreement procedure as a method of interpreting tax agreements and substantiates the qualification of the results of this procedure as official interpretation of double taxation, relevant for an indefinite group of persons. Unfortunately, the legal status of the results of mutual agreement procedures is not regulated anywhere. The author argues for the necessity of amending double taxation avoidance agreements to give the results of mutual agreement procedures binding force and also proposes a draft text of such amendments.