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Spread of the possibility of free movement of capital from one jurisdiction to another allows the companies incorporated in high-tax countries, to use low-tax or tax-free jurisdictions for conducting business and, as well as reducing tax burden. One of the mechanisms of tax evasion is the creation of controlled foreign companies that can delay the payment of dividends to the parent company, i.e. the payment of income that will be taxed in the country of tax residence of the parent company. The countries, in turn, adopt CFC rules (controlled foreign companies riles) to prevent tax evasion, which may change due to various circumstances. The CFC rules are aimed at determining the actual tax liability of the taxpayer. However, there are situations when CFC rules are implemented in a broader approach &amp;ndash; for example, a wide range of entities would fall under the definition of &amp;ldquo;controlled foreign companies&amp;rdquo; or &amp;ldquo;controlling entities&amp;rdquo;, which may result in the fact that the conditions for application of CFC rules may arise for the entities that do not exercise control over a foreign company. In this case, CFC rules can worsen the situation of the taxpayer. This creates an abuse of the right of controlling authorities in terms of preventing tax evasion. In order to avoid such situations, it is necessary to improve the CFC rules by limiting the circle of entities and clearly distinguishing between abuse of the rights and lawful actions in implementation of CFC rules.	

History of the emergence of legal regulation of activity of controlled foreign companies in the Russian Federation