Review: Modern international and cross-border relations in the sphere of public-private partnership (PPP) undergo transformations caused by globalization processes, which leads to the amendments in their legal regulation. The impact of non-state actors increases. Although the toolset for influencing cross-border relations in the sphere of PPP retains its legal core, it is being extended by the rules established by non-state actors outside the international and national legal systems, and carry no legal weight. For PPP as a form of interaction between the state and private investment and business structures, such transformations are particularly noticeable and require precise legal qualification. The scientific novelty of this research consists in providing definition in the international legal doctrine to Lex PPPs as the regulator of cross-border relations in the sphere of public-private partnership. Based on the dialectical, logical, and formal-legal methods, assessment is given to the role of international organizations in the formation of Lex PPPs. In conclusion, the author clarifies the role of Lex PPPs within the system of regulators of public-private partnership, namely that it should not expel the legal regulation of cross-border relations in the sphere of public-private partnership; as well as offers to seek for the new forms of correlation between international law and Lex PPPs and their consolidation through the international legal regulation of public-private partnership.

Keywords: non-state regulation, non-state actors, international non-governmental organisations, international intergovernmental organisations, cross-border relationships, public private partnerships, rule-making function, standardisation, lex mercatoria, lex PPPs

Review: Extension of globalization process to the world economy allows conducting the economic activity outside the country of tax residency. It also entailed the emergence of various types of incentives in some jurisdictions, for example, preferential tax regime or non-taxation. Questions related to international taxation are currently most acute. The use of foreign jurisdictions through controlled foreign companies reduces the state tax revenue. For counteracting abuse of the privilege by taxpayers, the rules of controlled foreign companies have been developed and implemented in over 30 countries. On the one hand, the countries accept these rules for preventing tax evasion, which can be changed due to various circumstances. On the other hand, there arise situations when such rules may worsen the situation of the taxpayer. This leads to abuse of the right of regulatory authorities in counteracting tax evasion. The controlled foreign companies (CFC) rules are aimed at determination of actual tax liability of the taxpayer, and do not pursue fiscal, political or other interests that worsen the conditions of the taxpayer.

Keywords: controlling persons, development of CFC rules, retained earnings of companies, CFC rules, controlled foreign companies, international tax law, tax liability, current tax liability, tax evasion, deoffshorization