Legal Mechanisms of Integration of International Tax Rules into the Domestic Legislation of the CIS Member States
Asmar Aliyeva
Abstract. This study systematically analyzes the institutional and normative mechanisms of integration of international tax norms into the national tax legal systems of the member states of the Commonwealth of Independent States (CIS). The central hypothesis of the article is that international legal influence in the field of taxation in the CIS is mainly carried out through advisory acts and voluntary cooperation mechanisms, which makes the integration process qualitatively different and limited in nature compared to supranational associations. The research methodology is based on the integrative application of formal-legal, comparative-legal and systematic analysis methods. The article examines four main integration mechanisms: (1) system of bilateral and multilateral tax treaties; (2) normative impact of the CIS Model Tax Code; (3) transplantation of the OECD Base Erosion and Profit Shifting (BEPS) plan into national legislation; (4) institutions of information exchange and administrative cooperation between tax authorities. The research findings show that while significant progress has been made in the areas of transfer pricing and information exchange, harmonisation of fundamental elements of tax policy remains limited due to economic differentiation, concerns over political sovereignty and the lack of binding legal mechanisms. The article presents recommendations for enhancing the legal status of the Model Tax Code, improving the digital tax administration infrastructure, and differentially using the experience of the Eurasian Economic Union to increase the efficiency of the integration process.
Keywords: Commonwealth of Independent States, international tax law, integration mechanisms, Model Tax Code, BEPS, transfer pricing, tax harmonization