On the problem of dividend taxation

• Piven' E.V.

• Rubinshteyn E.D.

The taxation of the foreign companies is an important problem. Foreign organizations in Russia pay actually all possible taxes of the system of taxation of Russian Federation, including tax on dividends, paid to the permanent agency of the foreign organization in Russia by another foreign organization. According to the actual Russian tax legislation there is no well-defined ground, which allows to define the way of taxation without ambiguity. It is exactly this question which is examined in the presented paper.