Maksimova, A.G. Comparative analysis of legal regulation of taxation of immovable property of physical persons in the Russian Federation and abroad (examples of the Great Britain and Germany)

Abstract: The article contains evaluation and comparative analysis of the elements in the taxation mechanisms in the Western European states, mostly, in the Great Britain and in Germany. The author singles out the main approaches towards taxation of immovable property, considering that their application in the Russian Federation shall facilitate formation of a more efficient legal system. In the Great Britain the immovable property tax is mostly a local tax, and it plays a significant role in the formation of local budgets. The author reviews two opposing positions in the sphere of taxation of immovable property. In Germany and in Russia the property tax is paid solely by the owner, and in the Great Britain it is also paid by the tenant. In Russia there is a very complicated system of inventory evaluation for the immovable property. It is stated that understanding and definition of immovable property is generally similar in different states. From a fiscal point of view the systems of taxation in the Western Europe are much more efficient than the analogous system in Russia today. The same may be said of the structure of legal regulation for the taxation system in Russia and abroad. The author makes propositions on what should be taken into consideration for the maximum fiscal efficiency in the taxation of property of natural persons in Russia.

Keywords: