scholarly journals Strategic Repositioning of Tax Administration in Nigeria Through Transfer Pricing

2021 ◽  
Vol 9 (5) ◽  
pp. 190
Author(s):  
Onyeka-Iheme Chimeruo Victory ◽  
Akintoye Ishola Rufus
Keyword(s):  
Transfer Pricing ◽  
Tax Administration

scholarly journals Applications of Blockchain in Taxation: New Administrative Opportunities

Webology ◽  
2021 ◽  
Vol 18 (Special Issue 04) ◽  
pp. 442-452
Author(s):  
Larisa Petrovna Grundel ◽  
Irina Aleksandrovna Zhuravleva ◽  
Olga Valentinovna Mandroshchenko ◽  
Anastasia Viktorovna Kniazeva ◽  
Yulia Yurevna Kosenkova
Keyword(s):  
Cost Effectiveness ◽  
Transaction Costs ◽  
Transfer Pricing ◽  
Fraud Detection ◽  
The State ◽  
Tax Administration ◽  
Smart Contracts ◽  
Tax System ◽  
Blockchain Technology ◽  
Data Structuring

The purpose of this article is to consider the prospects of using blockchain technology in taxation. The article discusses the essence of blockchain and its possible implementation in the tax system. The study focuses on the benefits of blockchain as one of the most promising methods of improving and simultaneously simplifying the tax system for both the state and taxpayers. The main focus of the study was on the specifics of the implementation of blockchain in tax administration, for example, data structuring, cost-effectiveness, security (fraud detection), decentralized accounting technology (transparency), verification of transfer pricing, and the use of smart contracts. Blockchain can reconstruct accounting and automate the method of payments, transfers, and asset accounting. In the conclusions, the authors identify such potential advantages of implementing blockchain in tax administration as reducing transaction costs, faster, more transparent, and efficient taxation function.

scholarly journals TRANSFER PRICES: PREREQUISITES FOR USE IN MANAGEMENT ACCOUNTING AND TAX ADMINISTRATION

2021 ◽  
Vol 2 (162) ◽  
pp. 71-77
Author(s):  
O. Vlasova
Keyword(s):  
Production Process ◽  
International Business ◽  
Negative Impact ◽  
Management Accounting ◽  
Transfer Pricing ◽  
Action Plan ◽  
Current Trend ◽  
Tax Administration ◽  
Transfer Prices ◽  
The Impact

Today, the issues of transfer pricing come to the fore in the ranking of current problems of tax administration not only in Ukraine but also in the world as a whole. This is due to the need for tax control to ensure price equality between related and independent entities in international business as a measure to combat the erosion of the tax base and the withdrawal of profits from taxation. The article presents a structured analysis of research by foreign and domestic scientists on transfer pricing in the field of management accounting or tax control. In particular, the grouping of views of scientists and practitioners on the nature and role in the accounting and analytical system of transfer pricing from the point of view of management accounting and tax administration. Study of the impact on the practice of transfer pricing methods of the picture of economic reality distorted by the negative impact of the COVID-19 pandemic. The need to use the transfer pricing mechanism in management accounting is due to the current trend of decentralization of management, and a prerequisite - the desire of top management to accelerate the production process, accelerate the turnover of equity and maximize profits. The advantages of using transfer pricing in management accounting to accelerate the production process and maximize profits, which led to the creation of corporations with the final technological cycle. It is also established that when deciding on the use of such a tool of internal pricing, one should keep in mind the cautions analyzed in the article. The preconditions for the introduction of tax control over transfer pricing in international business, as well as the basic laws and regulations in force in the global and Ukrainian economic space. The necessity and validity of the application of the OECD International Guidelines on Transfer Pricing, despite the provisions of Art. 39 of the Tax Code of Ukraine The ways of further development of tax control over transfer pricing within the framework of the BEPS Action Plan in Ukraine are considered. The need for further research on solving the problems of transfer pricing in the field of management accounting and taxation was identified, especially on the preparation of an information basis to justify the compliance of transfer prices with «Arm’s length principle».

scholarly journals The Peripatetic Nature of EU Corporate Tax Law

2019 ◽  
Vol 24 ◽  
pp. 1-60
Author(s):  
Christiana HJI Panayi
Keyword(s):  
Transfer Pricing ◽  
Tax Law ◽  
Tax Administration ◽  
Tax Rates ◽  
Corporate Tax ◽  
Tax Base ◽  
Potential Impact ◽  
Set Up ◽  
The Eu

This article examines some aspects of the European Union’s corporate tax set-up which correspond to aspects of a country’s corporate tax regime. The overarching question is whether there is such a thing as EU corporate tax law. This article seeks to address this in the context of the following issues: the existence of a uniform tax base and tax rates; the existence of anti-abuse rules and a transfer pricing regime; and, finally, the existence of a common tax administration and its powers. The article questions whether the peripatetic development of EU corporate tax law is suitable for the EU or whether it undermines its long-term objectives. The potential impact of Brexit in the development of EU corporate tax law is also addressed.

Questions of Regulation of Transfer Pricing in to the System of Tax Control of Russia

2018 ◽  
Vol 6 (3) ◽  
pp. 44-48
Author(s):  
Муслима Султанова ◽  
Muslima Sultanova
Keyword(s):  
Multinational Corporations ◽  
Transfer Pricing ◽  
Point Of View ◽  
Tax Administration ◽  
Tax System ◽  
Business Combinations ◽  
Integrated Structures ◽  
Small And Medium Business

In article the questions of tax control of the prices of transactions between vertically integrated structures of multinational corporations, holdings and other business combinations are considered. An assessment of modern model of tax administration, from the point of view of the preferences and privileges provided to corporations is given. Features of assessment of criteria of controllability of transactions and instruments of control of transfer pricing are revealed. Constructive proposals on realization of the stimulating capacity of tax system taking into account the interests of development of small and medium business are given.

scholarly journals Contributions of the Base Erosion and Profit Shifting BEPS Project on Transfer Pricing and Tax Avoidance

2021 ◽  
Vol 5 (3) ◽  
Author(s):  
Anissa Ouelhadj ◽  
Mehdi Bouchetara
Keyword(s):  
Literature Review ◽  
Transfer Pricing ◽  
Tax Avoidance ◽  
Multinational Companies ◽  
Qualitative Approach ◽  
Tax Administration ◽  
Short Term ◽  
Profit Shifting ◽  
Tax System ◽  
International Tax

Globalization and digitalization lead to flaws and asymmetries in tax rules which were used by multinational companies in their own benefit. Then, to face tax avoidance and tax losses which represents 100 to 240 billion dollars per year, Organization for Economic Co-operation and Development and G-20 implement, since 2012, the Base Erosion and Profit Shifting project, base erosion and profit shifting, which is the most important international reform that tax system has known. This paper aims to understand whether the Base Erosion and Profit Shifting project’s transfer pricing actions mitigate tax avoidance by multinationals through a literature review and a qualitative approach. We interview 05 international tax specialists working in Multinational Companies and Tax Administration. We found that the project’s transfer pricing reforms mitigate tax avoidance in short term. We confirm the first hypothesis, that the Base Erosion and Profit Shifting project’s transfer pricing inputs mitigate tax avoidance in the short term, and following the results obtained, we refute the second hypothesis that Base Erosion and Profit Shifting actions dealing with transfer pricing do not mitigate tax avoidance.

Tax systems taxpayer compliance and specific tax issues

2007 ◽  
Author(s):  
Mustafa Mohd Hanefah
Keyword(s):  
Transfer Pricing ◽  
Relevant Literature ◽  
Developed Countries ◽  
Assessment System ◽  
Tax Administration ◽  
Self Assessment ◽  
Compliance Costs ◽  
Research Findings ◽  
Tax Systems ◽  
Specific Tax

This book has eight chapters. Each chapter discusses one topic related to taxation. The topics covered in this book are tax systems, taxpayer compliance, compliance costs, transfer pricing, accounting malpractices and tax issues, taxation of ecommerce, and electronic tax administration. These topics are relevant to the advanced taxation course in the under-graduate and post-graduate programs (Masters and PhD). Each topic is discussed with relevant literature. The first three chapters touch on issues and problems related to the new tax administrative system i.e the self-assessment system, which is being implemented in developed countries including Malaysia, and is now being adopted for implementation in many developing countries worldwide. Chapters 2, 3 and 4 give an insight to issues related to tax systems, taxpayer compliance and compliance costs. The other four chapters 5, 6, 7 and 8 discuss topics that are categorised as selected tax issues. The selected tax issues include transfer pricing, accounting malpractices and tax issues, taxation of ecommerce and electronic tax administration. These issues have not been deliberated before, and it is timely that a book of this nature is published for tax authorities, researchers, students, lecturers, authorities and practitioners. Past literature and research findings are quoted to support the discussions in each chapter. The authors own research findings in certain topics found in this book are used to support the arguments and discussions.

scholarly journals CbC-REPORTING IN TAX ADMINISTRATION

2021 ◽  
Vol 116 (3) ◽  
pp. 64-76
Author(s):  
MUZYCHUK Mariana ◽  
FOMINA Olena
Keyword(s):  
Information Exchange ◽  
Business Processes ◽  
Transfer Pricing ◽  
Risk Identification ◽  
Comprehensive Analysis ◽  
Tax Administration ◽  
Tax Base ◽  
Use Of Data ◽  
Automatic Information ◽  
Reporting Data

Background. Countering the erosion of the tax base through the use of transfer pricing (TP) is an important element of tax policy. Ukraine is implementing three-level TP reporting and the procedure of automatic exchange of tax information. The analysis of recent research and publications has showedthat research on the use of data obtained in the exchange of tax information procedure under the CbC standard is relevant and controversial. The aim of the articleis to investigate the conditions for the introduction of automatic information exchange in Ukraine and provide recommendations for the practical use of the obtained data for tax control purposes. Results. An analysis of the structure of three-level TP reporting and the conditions of its first submission in Ukraine was performed. The procedure of automatic exchange of tax information according to the CbCR standard is considered. Based on the results of this study, a set of proposals for the use of CbC reporting data for tax administration purposes has been developed. The implementation of these proposals will help strengthen tax control and administration. Conclusion. The information received under CbCR-standard is intended for comprehensive analysis and risk identification by tax administrations and cannot be an alternative to tax audits or investigations. The obtained results can be used to build the business processes on CbC information application by the tax authorities. Further research in this direction should focus on the development of recommendations for the business process on the automatic exchange of information according to the CbCR standard establishment and the further use of the data obtained under this exchange by the tax administration.

scholarly journals Risk-oriented approach in tax administration of transfer pricing in Russia

2021 ◽  
pp. 66-72
Author(s):  
Ruslan Radzhabov
Keyword(s):  
Transfer Pricing ◽  
Practical Importance ◽  
Control Measures ◽  
Tax Administration ◽  
Market Prices ◽  
Market Participants ◽  
Transfer Prices ◽  
The Government ◽  
Oriented Approach

The protection of the sovereign tax base and determination of the “fair share of profit” that should be attributed to a particular jurisdiction remains one of the topical issues in Russia and worldwide. The instruments for determining fair profit include the mechanism of transfer pricing designated for calculating company profit of (member of corporate group) based on an analysis of the actual economic circumstances of making a transaction, i.e. the assets, functions and risks of the parties to the controlled transaction (leaning on the modeling of market prices using the methods of transfer pricing). Analysis is conducted on the risk-oriented approach in tax administration of transfer pricing in the Russian Federation. The scientific novelty consists in systematization of the approaches towards tax administration of transfer pricing and formulation of recommendations for improving the efficiency of current processes. The analysis of the practice of tax administration of transfer pricing and the corresponding case law indicates that in assessing the adequacy of prices in controlled transactions to the market level, the tax authorities apply the so-called “risk-oriented” approach aimed at determination of the segments/market participants/transactions with the highest risk of transfer pricing. The implementation of risk-oriented approach requires the development of risk profiles of transfer pricing, which, depending on the analyzed segment or subject matter of transaction, represent a list of tax control measures and circumstances (risk factors) that allow concluding on the presence of transfer pricing risk in such transaction. The practical importance of this research consists in the possibility of using the results the acquired results by the government bodies that carry out the functions of administering transfer pricing, as well as by the organizations that use transfer prices as the tax planning instrument.

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