Keyword: «double taxation»

The paper describes the development of the international legal framework on the regulation of double taxation, and also analyzes the latest regulatory acts in this area. The author draws attention to the similarity of such mechanisms as the main objective test in international law and the main objective principle in the national law of Russia. At the same time, the text of the article contains arguments that indicate a fundamental difference in these concepts. In her arguments, the author relies not only on the theoretical works of other researchers, but also studies in detail judicial practice. As a conclusion, the thesis is advanced that the main objective test is a tougher instrument that is gradually implemented in the Russian national legal system.