俄罗斯境外所得税收抵免制度简介与评析

An Introduction and Analysis of Russian Foreign Income Tax Credit System

本文主要研究和介绍俄罗斯境外所得税收抵免制度,为跨国企业提供指导与借鉴。俄罗斯的税收抵免制度包括国内法单方面规定的全额抵免和双边税收协定规定的限额抵免两种方式,均采用直接抵免法,没有税收饶让和间接抵免。虽在抵免时限和限额等方面尚有争议,但以立法的形式构建其基本制度,效力较强,同时因抵免方法及手续较为简单,纳税人负担轻,行政效率高。

This paper mainly studies and introduces the income tax credit system of Russia, and provides the guidance and reference for multinational enterprises. Russia’s tax credit system includes the full credit under domestic law and the limit credits under the bilateral tax treaties, which both adopt the direct credit method, and there is no tax sparing or indirect credit. Although there are still disputes over limit of time and credit, the basic system, constructed in the form of legislation, is more effective. At the same time, because of this simple method and procedure of credit, the taxpayer will have a light burden and administrative efficiency will be higher.