Tax sovereignty and tax jurisdiction: the relationship between concepts

The article examines the theoretical issues of tax sovereignty and tax jurisdiction of states as key concepts in international tax law. The purpose of the study is to define these concepts and establish their relationship. To achieve this goal, the author examines how the more generic concepts of "state sovereignty" and "state jurisdiction" are defined in the science of international law. Author pays special attention to the elements and types of state jurisdiction. Comparing the approaches of other researchers, the legal positions of the Constitutional Court of the Russian Federation and the provisions of international treaties, the author concludes that jurisdiction is not part of sovereignty, but sovereignty is the political and legal basis for the existence of jurisdiction. Based on these conclusions, the author analyses the concepts of "tax sovereignty" and "tax jurisdiction" and reveals the content of tax jurisdiction of the state. Using the example of the international treaty between the Russia and Kazakhstan regulating the status of the city of Baikonur, the author shows that a certain territory may be subject to the tax sovereignty of one state and at the same time subject to the limited tax jurisdiction of another state. The author uses general scientific methods (analysis and synthesis) as well as special methods of legal science (formal legal, comparative legal) in the course of the study. This study is primarily aimed at the development of the theory of international tax law, but the conclusions obtained as a result can be used to improve tax legislation and the provisions of international treaties on taxation. The author concludes that tax sovereignty is an integral part of sovereignty, which is a property of a state. Tax sovereignty serves as the foundation for tax jurisdiction, which can be defined as legal ability of the state to exercise powers in the field of taxation.