Advance Tax Rulings in the System of Tax Administration: International practices

Advance Tax Rulings in the System of Tax Administration: International practices

The research aims to assess the role of tax rulings in ensuring legal certainty, protecting taxpayers’ rights, and reducing tax dispute risks, while balancing private and public interests. The paper analyzes the conceptual and practical aspects of advance tax rulings, including definitions, legal na...

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Bibliographic Details
Main Authors: Mikhail D. Nadtochiy, Zlata V. Makarchuk, Alexander B. Zelentsov
Format: Article
Language:English
Published: Peoples’ Friendship University of Russia (RUDN University) 2025-07-01
Series:RUDN Journal of Law
Subjects:
advance tax rulings
public rulings
private rulings
legal certainty
tax administration
Online Access:https://journals.rudn.ru/law/article/viewFile/44982/24981
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Summary:The research aims to assess the role of tax rulings in ensuring legal certainty, protecting taxpayers’ rights, and reducing tax dispute risks, while balancing private and public interests. The paper analyzes the conceptual and practical aspects of advance tax rulings, including definitions, legal nature, types, objectives, and functions. Using comparative law, it investigates tax ruling practices in various jurisdictions, highlighting potential shortcomings and limitations. It compares rulings with the Russian practice of written tax law explanations from the Ministry of Finance and reasoned opinions from tax authorities, identifying the specifics of tax rulings as a tax and legal regulation instrument within tax administration. The research identifies the key characteristics of advance tax rulings, determines their legal nature, and analyzes the main types and functional purposes. It classifies tax rulings as private, public, and hybrid. The study reveals conceptual differences between tax rulings and reasoned opinions and written explanations of tax legislation in Russian tax law. Finally, it formulates proposals for modernizing Russian tax legislation, incorporating best international practices for advance tax ruling regulation.
ISSN:2313-2337
2408-9001

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