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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| Format: | Article |
| Language: | English |
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Peoples’ Friendship University of Russia (RUDN University)
2025-07-01
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| Series: | RUDN Journal of Law |
| Subjects: | |
| Online Access: | https://journals.rudn.ru/law/article/viewFile/44982/24981 |
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| author | Mikhail D. Nadtochiy Zlata V. Makarchuk Alexander B. Zelentsov |
| author_facet | Mikhail D. Nadtochiy Zlata V. Makarchuk Alexander B. Zelentsov |
| author_sort | Mikhail D. Nadtochiy |
| collection | DOAJ |
| description | 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. |
| format | Article |
| id | doaj-art-3d5dea7adbc241a1bcae9045c0e0c613 |
| institution | Kabale University |
| issn | 2313-2337 2408-9001 |
| language | English |
| publishDate | 2025-07-01 |
| publisher | Peoples’ Friendship University of Russia (RUDN University) |
| record_format | Article |
| series | RUDN Journal of Law |
| spelling | doaj-art-3d5dea7adbc241a1bcae9045c0e0c6132025-08-20T03:50:39ZengPeoples’ Friendship University of Russia (RUDN University)RUDN Journal of Law2313-23372408-90012025-07-0129236538110.22363/2313-2337-2025-29-2-365-38121284Advance Tax Rulings in the System of Tax Administration: International practicesMikhail D. Nadtochiy0https://orcid.org/0000-0002-9227-2622Zlata V. Makarchuk1https://orcid.org/0000-0001-7859-1355Alexander B. Zelentsov2https://orcid.org/0000-0002-6496-8905RUDN UniversityRUDN UniversityRUDN UniversityThe 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.https://journals.rudn.ru/law/article/viewFile/44982/24981advance tax rulingspublic rulingsprivate rulingslegal certaintytax administration |
| spellingShingle | Mikhail D. Nadtochiy Zlata V. Makarchuk Alexander B. Zelentsov Advance Tax Rulings in the System of Tax Administration: International practices RUDN Journal of Law advance tax rulings public rulings private rulings legal certainty tax administration |
| title | Advance Tax Rulings in the System of Tax Administration: International practices |
| title_full | Advance Tax Rulings in the System of Tax Administration: International practices |
| title_fullStr | Advance Tax Rulings in the System of Tax Administration: International practices |
| title_full_unstemmed | Advance Tax Rulings in the System of Tax Administration: International practices |
| title_short | Advance Tax Rulings in the System of Tax Administration: International practices |
| title_sort | advance tax rulings in the system of tax administration international practices |
| topic | advance tax rulings public rulings private rulings legal certainty tax administration |
| url | https://journals.rudn.ru/law/article/viewFile/44982/24981 |
| work_keys_str_mv | AT mikhaildnadtochiy advancetaxrulingsinthesystemoftaxadministrationinternationalpractices AT zlatavmakarchuk advancetaxrulingsinthesystemoftaxadministrationinternationalpractices AT alexanderbzelentsov advancetaxrulingsinthesystemoftaxadministrationinternationalpractices |