Olender I. Legal regulation of tax liability fulfillment in the elimination of double taxation regime

Українська версія

Thesis for the degree of Doctor of Science (DSc)

State registration number


Applicant for


  • 12.00.07 - Адміністративне право і процес; фінансове право; інформаційне право


Specialized Academic Board

Д 17.051.07

Zaporizhzhia National University


In the dissertation the problem of double taxation, which has a cross-border and transnational character, is considered in combination with the characteristics of general theoretical constructions of "tax obligation", "tax liability", analysis of their structural elements and study of tax liability procedures. The sectoral specificity of the legal obligation in the regulation of tax relations is determined, the fundamental difference between the constructions "tax obligation" and "tax liability" is established, which consists in a different balance of rights and obligations of the obligated and authoritative subject in tax relations. The comparative legal characteristics of the use of the constructions "tax obligation" and "tax liability" in their national tax laws are given. The influence of international tax agreements on the construction of the double taxation regime is characterized. Thanks to the norms of international tax agreements, it is possible to achieve greater certainty in the fiscal regimes of different countries and to establish effective mechanisms for mutual assistance and exchange of information on the activities of taxpayers. The case law of resolving double taxation disputes in the countries of the European Union and the United States of America is generalized.


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