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In the article the author considers the problems of apportionment of the burdens in tax disputes, which arise in case requalification of taxpayer’s income and transactions. This article based on the legal analysis of national anti‐avoidance rules and case law in tax requalification context.


Tax disputes, legal requalification, tax planning, burden of proof, anti‐avoidance rules.

The apportionment of the burdens in case of tax controversy about the legal qualifi‐ cation of taxpayer’s income and transactions

Rakov I. A. i.ruckov.soeb@gmail.com

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