IMPLEMENTATION OF THE REQUIREMENTS OF INTERNATIONAL TRANSFER PRICE FORMATION AT THE ENTERPRISES OF UKRAINE: FEATURES AND PROSPECTS

Author(s):  
O.Yu. Miroshnychenko ◽  
◽  
M.M. Karpushyna ◽  

The features of transfer pricing in Ukraine have been considered. It has been established that transfer pricing in Ukraine is at the stage of formation. The features and prospects for the implementation of international transfer pricing requirements using the «Three-tier model of transfer pricing documentation recommended by the OECP (step 13 of the BEPS plan)» have been identified. The legal aspects of regulating the prevention and minimization of the movement of profits, tax evasion by transnational corporations, in particular, the BEPS package, and others have been considered. The place of Ukraine in the Paying Taxes rating in 2015-2020 is determined. Trends 2015-2020 testify to the formation of tax discipline regarding the timeliness and completeness of reporting on transfer pricing. The dynamics of the submitted reports on controlled transactions in Ukraine in quantitative and value terms in 2013-2020 has been analyzed. The volume of controlled transactions by country and by subject of transactions in 2020 was investigated. It was found that the largest share in the total volume of controlled transactions is occupied by banking services (37%) and transactions with goods (35%), and the largest volume of controlled transactions is carried out in Switzerland. The features of the implementation in Ukraine of the BEPS plan as an international project of the Organization for Economic Cooperation and Development (OECD) and the G20 countries are considered. The innovations in tax legislation in the field of transfer pricing and the peculiarities of introducing a three-level reporting structure on transfer pricing in Ukraine have been described. The World Transfer Pricing 2022 rating of Ukrainian companies offering transfer pricing services is presented. The problems that hinder the effective implementation of the requirements of international transfer pricing in Ukraine have been identified and measures have been proposed that should be taken to overcome them.

Author(s):  
Zakharii Varnalii ◽  
◽  
Tetiana Stytsenko ◽  

The article considers the essence of the tax burden of business entities, identifies the reasons for optimizing the tax burden and tax evasion, defines the nature, types and stages of planning the tax burden of the enterprise, reveals in detail the methods and tools of tax optimization. The level of tax burden on the economy of Ukraine and its place among the countries of the world according to the World Bank is studied, and also the level of development of the taxation system and assistance to business development in Ukraine is determined. It is substantiated that the economic situation of the country and the need for the formation of budget revenues are factors of a disproportionate tax burden on business entities. It is established that the imperfection of tax legislation and the organization of the taxation process adversely affect businesses, which in turn are forced to resort to illegal methods of reducing the tax burden and evade taxes. It is proved that for domestic enterprises in order to adapt to the constant transformations of the environment, tax optimization (in particular, legal) is a mandatory tool of corporate financial management at every stage of their life cycle: in the period of formation, growth, stability and especially in decline. The study used a significant amount of information sources, including: legislation governing tax relations; materials of profile and periodicals; statistical information. To obtain results and form a conclusion, methods of theoretical analysis were used - abstraction, analysis and synthesis, induction and deduction, ascent from the abstract to the concrete, as well as methods of empirical research - observation, comparison.


2018 ◽  
Vol 64 ◽  
Author(s):  
A.V. Kovalenko

The article analyzes the change in the development of decentralization in the world. Highlighted its problems and species. Analyzed the activity of local budgets of Ukraine. They found that decentralization reform increased local budget revenues. Such a result enables to develop the regions of the country. They analyzed taxes that could improve the financial condition of enterprises. Thus, the tax on withdrawn capital will be able to increase profits for enterprises, optimize the work of the tax service and simplify the accounting of taxes for accountants. Highlighted the main problems of the tax system. The constant change of the tax code makes it more difficult for perception. Also, due to constant changes, the tax code is not accurate and has many loopholes for tax evasion. Therefore, the simplification of tax legislation will make it more workable.


2014 ◽  
Vol 1 (2) ◽  
pp. 187
Author(s):  
Serdar KUZU

The size of international trade continues to extend rapidly from day to day as a result of the globalization process. This situation causes an increase in the economic activities of businesses in the trading area. One of the main objectives of the cost system applied in businesses is to be able to monitor the competitors and the changes that can be occured as a result of the developments in the sector. Thus, making cost accounting that is proper according to IAS / IFRS and tax legislation has become one of the strategic targets of the companies in most countries. In this respect, businesses should form their cost and pricing systems according to new regulations. Transfer pricing practice is usefull in setting the most proper price for goods that are subject to the transaction, in evaluating the performance of the responsibility centers of business, and in determining if the inter-departmental pricing system is consistent with targets of the business. The taxing powers of different countries and also the taxing powers of different institutions in a country did not overlap. Because of this reason, bringing new regulations to the tax system has become essential. The transfer pricing practice that has been incorporated into the Turkish Tax System is one of the these regulations. The transfer pricing practice which includes national and international transactions has been included in the Corporate Tax Law and Income Tax Law. The aim of this study is to analyse the impact of goods and services transfer that will occur between departments of businesses on the responsibility center and business performance, and also the impact of transfer pricing practice on the business performance on the basis of tax-related matters. As a result of the study, it can be said that transfer pricing practice has an impact on business performance in terms of both price and tax-related matters.


2010 ◽  
Vol 2 (2) ◽  
pp. 103-117 ◽  
Author(s):  
Padraic Kenna

PurposeThe purpose of this paper is to outline and examine the growing corpus of housing rights and assess their relevance and applicability to complex contemporary housing systems across the world.Design/methodology/approachThe paper sets out the principal instruments and commentaries on housing rights developed by the United Nations, regional and other bodies. It assesses their relevance in the context of contemporary analysis of housing systems, organized and directed by networks of legal and other professionals within particular domains.FindingsHousing rights instruments are accepted by all States across the world at the level of international law, national constitutions and laws. The findings suggest that there are significant gaps in the international law conception and framework of housing rights, and indeed, human rights generally, which create major obstacles for the effective implementation of these rights. There is a preoccupation with one element of housing systems, that of subsidized or social housing. However, effective housing rights implementation requires application at meso‐, micro‐ and macro‐levels of modern, dynamic housing systems as a whole. Epistemic communities of professionals develop and shape housing law and policy within these domains. The housing rights paradigm must be further fashioned for effective translation into contemporary housing systems.Research limitations/implicationsThe development of housing rights precedents, both within international and national law, is leading to a wide and diffuse corpus of legislation and case law. More research is needed on specific examples of effective coupling between housing rights and elements of housing systems.Originality/valueThis paper offers housing policy makers and lawyers an avenue into the extensive jurisprudence and writings on housing rights, which will inevitably become part of the lexicon of housing law across the world. It also highlights the limitations of housing rights implementation, but offers some new perspectives on more effective application of these rights.


2021 ◽  
Vol 298 (5 Part 1) ◽  
pp. 219-222
Author(s):  
Ludmila Oleinikova ◽  

The expediency is reasoned of creating a competitive environment in the context of globalization and limited factors of production, forcing countries to compete with each other and take measures to attract owners of factors of production by forming the optimal combination of institutional, public goods and tax preferences, where only tax preferences are not the key to success in competition, as opposed to general conditions of taxation in combination with infrastructural, institutional and public goods. Emphasis is placed on the rapid digitalization of economic processes and the globalization of even small businesses through online platforms that will significantly affect the struggle in the field of economic and institutional competition. It has been proven that it is already necessary to respond to new challenges which are associated with tax evasion, erosion of the tax base, a significant geographical gap between the location of factors of production and the jurisdiction of profit. It is established that the answers to these risks lie both in the plane of institutional readiness and in the plane of the effectiveness of the application of tax administration tools, including control, as well as the synergy of measures at the macro and micro levels. The variety of tools used in world practice to improve compliance with tax legislation is studied and their division into categories is indicated. The expediency of using mechanisms to ensure the transparency of the tax system is substantiated, along with measures to assure the transparency of taxpayers before the tax authorities at the national level, as well as mechanisms to provide accountability and transparency of the tax authorities themselves to the government, parliament and taxpayers. It is proposed, taking into account foreign experience, in addition to quantitative indicators of tax effectiveness, to use supplementary indicators that characterize the work of tax authorities, considering economy, effectiveness, efficiency, which will deepen the level of tax system performance.


Telaah Bisnis ◽  
2018 ◽  
Vol 18 (1) ◽  
Author(s):  
Dekeng Setyo Budiarto ◽  
. Yennisa ◽  
Fitri Nurmalisa

Abstract Tax compliance has long been an issue for governments throughout the world and there is a large and rich research literatur in this field. This study examines the influence religiosity,and machiavellian on the tax evasion based from gender. The sample of this study are 202 account­ing students from 8 private university of Special Region of Yogyakarta. The results of the study prove that religiosity has significant influence on tax evasion, while machiavellian has no sig­nificant influence on tax evasion. Moreover, there is significant different on tax evasion based from gender. The results are expected for the government to designing policies to prevent tax evasion.


Author(s):  
Volodymyr Metelytsya

The regulation of the professional activities of accountants either promotes business development, the migration of financial and human capital, or complicates this process. Many firms with global interests may already be feeling the burden of complex and ever-changing regulations issued at domestic and international level. It is expected that some regions of the world are likely to face far more regulation of financial activities, including accounting. The purpose of the article is to analyze the latest changes in the regulation of the professional activity of accountants caused by the transformations of the global economic system, as well as to identify and assess the challenges that accountants around the world will face in the coming years. The tendencies in the field of regulation of professional activity of accountants in Europe, USA, Australia, Asia were revealed, and the factors (reasons) of their development were determined. In particular, in Europe, there are growing calls for more regulation in finance and “fairness” in tax especially when it comes to taxing digital corporations, whereas in the US, things are moving in the opposite direction, with less regulation to encourage growth. Across the Asian region, banking and corporate regulation is becoming more stringent and the expectations of revenue authorities around issues such as transfer pricing documentation are increasing. It has been determined that the existence of accounting standards and rules as such does not guarantee reliable and appropriate financial indicators, and therefore the role and importance of professional ethics increases. Three key areas of change and challenges for the accounting profession that will take place in the coming years were assessed. It has been proven that the goal of strengthening regulation around the world is to solve socio-economic and environmental problems. It is important for accountants to realize that such events should develop motivation not to manipulate numbers, as well as ensure the introduction of a system of fair taxation and elimination of abuses by the subjects of the digital economy. So, all over the world there is a real need to educate accountants on the changing global regulatory framework.


Author(s):  
Oldřich Tvrdoň ◽  
Radmila Presová ◽  
Martin Přibyl

The thesis “Economic-legal aspects of business assets definition and its effectiveness analysis” analyses the contribution of business assets in joint-stock company Svornost Těmice. The company operates in the field of agricultural primary production. Focus of plant production still keeps the traditional composition of plants grown. In connection with increasing the quality of effectiveness of the machinery the area of corn-production will be expanded. In animal production, the company specialises on the pig-feeding and milking-cows.The theoretical part includes the opinions of the world economists and managers on the definition of basic concepts related to business assets. These opinions are confronted with those of Czech authors, in order to acquaint students of the Faculty of Business and Economics with them – focusing on students of the Trade Management specialisation.The practical part is focused on analysis of effectiveness of business assets in the selected company. It have confirmed that managers of this business have to improve the intensity of exploitation of the asset base and thus to reach its higher effectiveness. This task is necessary for operation in the intensive-competition environment formed after the entrance into the European Union.


2016 ◽  
Vol 6 (4) ◽  
pp. 442-447
Author(s):  
Emmanuel Innocents Edoun ◽  
Alexandre Essome Dipita ◽  
Dikgang Motsepe

Africa is facing a number of challenges that are negatively affecting socio-economic development at all levels of governments and local governments are expected to play a leading role for Africa’s development. One of these challenges are illicit financial flows that are perceived by many as a crime against Africa’s transformation. The continent is losing billions of dollars every year because of tax evasion, corruption and inappropriate transfer pricing and maladministration. With tax being one of Africa’s main sources of revenue, current and past researches revealed that, illicit financial flows (IFFs) cripple African Governments tax base as a results of capital outflows and lack of good governance. This situation obviously is a challenge for Africa’s development as governments struggle to finance structuring projects and this in turn compels these governments to seek funds from international organisations at very high interest rates. It is also important to reveal that Foreign Direct Investment (FDI) rapidly grew after the Second World War with the intention to maximize profit on investment in less developed countries and specifically in the African continent. In competing in Africa, most multinationals main objective is to pay less tax, make extensive profits and transfer the proceeds to their country of origin. This subsequently gave rise to illicit financial flows in Africa where the continent is losing billions of dollars. Past studies equally revealed that, Africa’s revenue could increase between 55 and 65%, if appropriate mechanisms of monitoring the flows were in place. This study therefore is based on the premise that, tax evasion, illicit financial flows, corruption and abusive transfers pricing are all factors that affect Africa’s development. Using appropriate method of inquiry, this study wants to demonstrate the presence of FDI’s in Africa as a modus operandi behind tax evasion. It also using the “Appropriability Theory” to explain the rationale for FDI in Africa.


Author(s):  
Anil Vashisht

<div><p><em>This paper studies the impact of IT in the service quality of banking sector. The purpose of the intended research involves determining bank adoption pattern of electronic media, factors constituting drivers and inhibitors for bank adoption, dimensionality of e-banking services quality as affected by IT, and customer adoption of such services. The study has also highlighted the determinants of service quality are directly influenced by IT and to explore what are the enabling and retarding factors for effective implementation and upsurge of IT system in banks.</em></p></div>


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