Mutual agreement procedure (MAP) is an important instrument for resolving disputes on taxation not in accordance with the provisions of double taxation agreements. Nevertheless, its potential was not applied widely neither by taxpayers nor by the competent authorities in Ukraine. In 2020, the national legislator introduced changes to the Tax Code of Ukraine that might positively impact on the practice of application of MAP in Ukraine and make it more certain and comfortable for taxpayers and tax authorities. The taxpayers received the right to initiate MAP between competent authorities of contracting states in case of taxation not in accordance with the provisions of double taxation treaties. At the same time, the new legal provisions have few deficiencies in comparison with the international standards of international taxation included in the OECD MTC and its commentaries. Based on the results of the comparative analysis, the amendments to the Tax Code of Ukraine are proposed in the article.

Evolution of Russian(Soviet)-Japanese relations from 1699 to 1941

Russian(Soviet)-Japanese contacts have a tradition of over 300 years. The author focuses in the article on a brief exemplification and analysis of unofficial Russian-Japanese contacts since the 18th century and their official relations until the signing of the Treaty of Neutrality between the Soviet Union and Japan in April 1941. In total, four parts of the article are devoted to the analysis, apart from the introduction and conclusion. The first part of the article covers the period of unofficial relations between the two countries, which was characterized by two contradictory tendencies. Russia is pursuing territorial expansion towards the Pacific Ocean, while Japan maintains a policy of voluntary closure to the outside world. The second part deals with the official relationship between them from the Treaty of Shimoda to the Russo-Japanese War of 1904–1905. During this period, both countries are guided by a policy of territorial expansion, which led to a war between them. The third part is related to the period from the signing of the Portsmouth Peace Treaty in 1905 to the fall of the Romanov dynasty in 1917. This was the only period of mutual friendship between Russia and Japan. The last part was the years from the February and October Revolutions in Russia to the conclusion of the neutrality pact in April 1941. At that time, one of the external interventions against Soviet Russia was Japan. However, after the Japanese troops were driven out of Soviet territory in the Far East, the two countries establish official diplomatic relations. In the 1930s, mutual relations deteriorated, and in the complicated international situation that existed at the time, Moscow and Tokyo signed the Neutrality Pact in April 1941. At the end of the article, several conclusions were formulated.