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Caucasus and Central Asia in the Globalization Process 294 To help attract further investments in countries, corporate income tax laws and transfer pricing laws should be amended so that the rules for setting prices in intercompany transactions are based on OECD transfer pricing guidelines. The legislature reforms should also address the procedure for competent authorities to use inexamining cross border disagreements between related parties in cases that involve a trading partner of Russia and Azerbaijan that has entered into and ratified a tax treaty. Tax payers should also have the opportunity to enter into safe harbors with advance pricing agreements with the tax authorities for related-party transactions - a practice that currently does not exist in either country. 33 Tax Audit Rules and Administration must be modify to better protect legitimate rights and interests of taxpayers. Legislation and regulations affecting investors should be improved to ensure a favorable climate to the foreign investors. There are also some problems in tax audit processes of both countries. Fo example; although tax legislation in Russia has moved closer to OECD norms, it is not unusual for tax auditors to ignore key provisions of the tax laws or of contracts. It is also proving difficult for audit issues to be closed and resolved, and taxpayer rights can regularly be thrown out the window by a declaration of ‘‘badfaith.’’ In Russia, 16 months after Putin’s State of the Nation address (March2005), in which he declared the need to stop ‘‘tax terrorism’’ by reining in the unchecked powers of the tax administration. Also in Russia, a number of important pro-taxpayer amendments survived the turbulent legislative process. The result was alimitation of the Ministry of Interior’s powers to initiate tax-related criminal charges against taxpayers until after obtaining a court order. 34 REFERENCES − BLACK, Sam, Erik BRITTON, Adrian COOPER, Terence G. PERRIS and Daniel A. WITT (2004 ): “Taxes on Profits of Multinational Companies and Implications for Russia” Tax Perspective, April. − CHOWN, John (2005): “Financial Markets in Emerging and Transitional Countries”, ITIC Special Report, The Taxation Systems, Investment Regulation and Economic Development in Select Countries of Eurasia, March. − DANIEL, Philiph & Adrian FERNANDO (2004): “Reforming Taxation of Oil Sector in the Russian Federation”, ITIC Special Report, December. − FABRY N., Zeghni S., (2002): “Foreign Direct Investment in Russia: How the Investment 33 Daniel A. 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(1998): “Evaluation of Taxes And Revenues From The Energy Sector In The Baltics, Russia And The Other Former Soviet Union Countries”, IMF Fiscal Affairs Department, WP/98/34. − IMF (2005): Azerbaijan Republic: Selected Issues, IMF Country Report No: 05/17, January. − IMF (2005): Azerbaijan Republic: Statistical Appendix, IMF Country Report No. 05/18, January. − ITIC (2005): The Taxation Systems, Investment Regulation and Economic Development in Select Countries of Eurasia, ITIC Special Report, March. − ITIC (2006): Some Fiscal Parameters of the Investment Climate in Select Countries of Eurasia, ITIC Special Report, May. − IVANOV Vladimir I., (2005): “Russia’s Energy Politics: Focusing On New Markets in Asia”, The Symposium of New Paradigms for Transpacific Collaboration, KIEP- KEI, 16–18 October, Seattle. − LEJEUNE, Ine (2006): “VAT/GST: The Win-Win Taxa- tion Systems of the Future?”, The World Bank & Price WaterHouseCoopers, Paying Taxes: The Global Picture. − LORIE, Henri (2003): “Priorities for Further Fiscal Reforms in the Commonwealth of Independent States”, IMF Working Paper WP/03/209. − METCALF Gilbert E., (2006): “Federal Tax Policy Towards Energy” National Bureau of Economic Research, NBER Working Paper No. 12568. − PAGE, Bill (2006): “An Overview of Transfer Pricing Law in the CIS”, Some Fiscal Parameters of the Investment Climate n Select Countries of Eurasia, ITIC Special Report, May. − PRICEWATERHOUSECOOPERS &THE WORLD BANK (2006): Paying Taxes: The Global Picture. − SAAVALAINEN, Tapio & Joy ten BERGE (2006): “Quasi-Fiscal Deficits and Energy Conditionality in Selected CIS Countries”, IMF Working Paper WP/06/43. − SAUNDERS, Roy (2007): “Understanding Double Tax Treaties”, http://www.itpa.org/open/archive/saundersunder.rtf (28- 03-2007) − SHATALOV, Sergey (2006): “Tax Reform in Russia—History And Future”, Tax Analsts, Tax Notes International Volume: 42, Number: 9, May 29. − SHIELLS, Clinton R. (2003): “FDI and the Investment Climate in the CIS Countries”, IMF Policy Discussion Paper PDP/03/5, November. − STEPHANYAN, Vahram (2003): “Reforming Tax Systems: Experience of The Baltics, Russia and Other Countries of The Former Soviet Union”, IMF Working Paper WP/03/173, September. − SUNLEY, Emil M. , Thomas BAUNSGAARD and Dominique SIMARD (2002): “Revenue from the Oil and Gas Sector: Issues and Country Experience”, Background paper prepared for the IMF Conference on Fiscal Policy Formulation and Implementation in Oil Producing Countries, June 5-6, 2002. − VOIGT Peter, (2006): “Russia’s Way From Planning Toward Market: A Success Story? A Review of Economic Trajectories, Transition Progress and Putin’s Merits”, Post-Communist Economies, Vol. 18, No. 2, June. Yüklə 1,5 Mb. Dostları ilə paylaş:
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