scholarly journals Transfer pricing as a means of the state tax base optimization

Author(s):  
A. Krutova ◽  
O. Nesterenko ◽  
M. Levina

This study is aimed at development of the theoretical foundations of transfer pricing mechanism implementation at Ukrainian enterprises. Methods. The article uses processed by analytical alignment data of pricing methods analysis. Achievement of the objectives was carried out with help of general and special research methods, namely: dialectical approach, analysis and synthesis, systematization and generalization Results. Developed classification of pricing models is presented in this research with separation of the transfer pricing methods group, which are an effective tool of international tax planning transparency increasing, taxation stability ensuring and eliminating the possibility of moving profits to other tax jurisdictions. Transfer price formation stages matrix is developed which divides transfer pricing process on five stages: data collection, functional analysis, economic analysis, accounting procedures, reporting. The study tested the possibility of implementation in Ukraine of steps 8-10 of the BEPS plan as relevant for solving problems caused by tax base erosion. Conclusions. Developed in the article matrix of the transfer price formation stages will contribute to effective implementation of BEPS steps relating to pricing control.

This study is aimed at development of the theoretical foundations corporate control systems modeling for biotech companies.Methods. The article uses the data about specialties of Ukrainian partnerships in biotech industry corporate control distribution. These data are processed by analytical alignment. Achievement of the objectives is carried out with help of general and special research methods, namely: dialectical approach, analysis and synthesis, systematization and generalization Results. It is proved that the biotechnology market is the most dynamically growing segment of the "new economy" that requires special attention from the mechanism of corporate control implementation and distribution. Research presents the mechanism of leveling corporate conflicts situations, distributed according with the levels of the partnership’s architectural model. The appropriateness of expanding the corporate control mechanism motivational component by means of reflexive management tools has been developed. The scheme of integrating reflexive management tools into the component of information provision of the mechanism of corporate control is determined. Conclusions. The material presented in the article has a practical significance because, according to the results of the study proposed mechanism allows to direct reflexive influence on formation among stakeholders a proper vision of corporate control system architecture and content of its elements.


2020 ◽  
Vol 26 (5) ◽  
pp. 991-1016
Author(s):  
A.G. Lukin

Subject. This article explores the main points of the theory of financial management, developed within the framework of the Western general theory of finance, and the theory of financial management developed in the Soviet Union. Objectives. The article aims to substantiate an idea that these theories are complementary, and their harmonious application can help build the most effective system of financial relations management at both the macro-and microeconomic levels. Methods. For the study, I used a dialectical approach and the methods of comparison, analysis and synthesis, and historical analysis. Results. The article substantiates the point that the methodology of Western financial management theory is aimed at managing external financial flows and combating external financial risks. It notes that the Soviet theory regulates methods and techniques of financial management within the business entity or the State. Conclusions. Theoretical updating of the Soviet practices of financial management combined with the modern achievements of financial management theory will create conditions for the formation of an optimal financial management structure at both the micro-and macroeconomic levels. This can improve the efficiency of financial management, in general. Renewed interest in the theoretical developments of the Soviet Union will contribute to the development of financial science at the present stage.


2019 ◽  
Vol 4 (3) ◽  
pp. 237-244
Author(s):  
Mikhailo KOBCHENKO

Introduction. The purpose of this article is to define methodological grounds of assessment of agricultural land using efficiency. The article is devoted to definition of the indicators system of land using efficiency. Methods of research. The solution of the tasks in the article is carried out with the help of such scientific and special research methods as: analysis and synthesis, systematization and generalization, the dialectical approach. Results. The structural balance between cost of land and production resources has been investigated, which leads to the need of many alternatives for the purpose and use of the respective territories on the basis of the modern system of land using efficiency assessment when determining the benefits of land resources using for agricultural production. Originality. It has been proved that to create and enforce a uniform indicators system of land using efficiency is necessary to determine all the factors that affect land use, to reflect the degree and type of each factor influence using the indicators of efficiency of the land use. Indicators of economic efficiency of land using and the intensity of land use are systemized. Practical importance. The methodical approach of agricultural lands using evaluation in the following areas has been justifed in the article: completeness of land use, rational land use, the level of land use intensity, efficient land use. The methodical approach has been presented to the calculation of potential losses from specific land uses in specific circumstances. It is proposed to assess the land using efficiency on the basis of indicators calculations of environmental and economic damage. Basic scientific principles can be used in the practice of agricultural enterprises. Keywords: management, methodological bases, evaluation, efficiency, and agricultural land use.


2021 ◽  
Author(s):  
Tat'yana Maslevich

The textbook examines the theoretical foundations of business process management of a modern enterprise, presents a practical approach to the identification, classification of processes and implementation of process management, which can be applied in practice in the activities of organizations in the context of innovation and digital transformation of business. At the end of the chapters, there are questions, test and practical tasks for the purpose of self-control on the development of the material. Meets the requirements of the federal state educational standards of higher education of the latest generation. It is recommended for use by teachers, undergraduate and graduate students and students of MBA programs studying in economic disciplines, management and management activities, as well as specialists of economic, consulting, innovation, and planning departments of enterprises.


Author(s):  
Alexander A. Somkin

Introduction. The paper analyzes the specificity of the dialectical development of the integrated social systems of such a personality and society. The presence of positive (natural) contradictions is recognized as a necessary and creative factor in social practice. Under the influence of this type of contradiction, the old, outdated forms of social structure (individual components of the social system) are denied and transformed to new, more perfect ones occurs as a result of their successful resolution. Methods. In the analysis, the author relied on a system-holistic approach, traditional general philosophical methods: induction and deduction, theoretical analysis and synthesis, extrapolation, etc. Discussion. The social system as an integrated unity goes through a number of stages from inception, formation and maturity to the transition to a qualitatively new state. Accordingly, the process of the emergence and development of dialectical contradictions also has several stages: from insignificant differences between opposite sides at the beginning of the emergence of the system to their strengthening and exacerbation. The nature of the contradictions depends on the specifics of the opposing sides, as well as on the conditions in which their interaction unfolds. The determining factor here, in the opinion of the author, is the positive (natural) direction of social opposition, under the influence of which the essence of the contradictions themselves is formed. Conclusion. According to the dialectical approach, the source of social development is the unity and struggle of opposites within the social system. However, the presence of opposite sides is a necessary but insufficient condition for development. They create the preconditions for it, but do not act as its driving force. Only a change in one opposition relative to another creates alternative tension, giving rise to a dialectical contradiction. Therefore, the antagonistic or non-antagonistic character of the latter is due to the positive (natural) or negative character of the social opposition itself.


1973 ◽  
Vol 1 (4) ◽  
pp. 409-425 ◽  
Author(s):  
Robert E. Berney ◽  
Bernard H. Frerichs

The concept of income elasticity of tax revenues has been used in numerous studies with little concern about its theoretical foundations. Income elasticities have also been used for revenue estimation with limited concern about stability over time or about the accuracy of the forecasts. This paper explores the development of the tax elasticity measure and, using revenue data from Washington, compares year-to-year elasticity measures with those established by regression analysis. The length of the time series is varied to check on the stability of the coefficients. Finally, the elasticities are used to predict revenues for three years to check on their accuracy for revenue estimation.


2019 ◽  
Vol 23 (1) ◽  
pp. 48-61
Author(s):  
Valeriy P Ivanskiy ◽  
Sergey I Kovalev

The relevance of the article, which consists of two parts, is that the various theories of rationality presented only in philosophical works are considered. Meanwhile, it should be noted that in recent decades in scientific works on jurisprudence there is a clear trend of borrowing such terms from philosophy as «classical», «non-classical» or «post-non-classical» science in the description of a concept of law. Nevertheless, in legal studies there is still no concept of rationality, the criteria for its classification, allowing to describe the diversity of manifestations of legal reality. The purpose of the study is: 1) to find new non-classical foundations for the development of legal knowledge; 2) to substantiate the point of view that the category of "scientific rationality" and its typology used in philosophy, it is necessary to introduce into scientific use of legal science, which will push the boundaries of knowledge of legal reality; 3) to describe the features of understanding of the term "scientific rationality" in law in the context of its classification into the following two groups: classical and neoclassical (post-classical), as well as non-classical and post-classical. In the process of studying the philosophy of rationality in legal studies used a diverse set of methodological tools: 1) General philosophical methods (dialectical and idealistic); 2) General scientific methods - analysis and synthesis, deduction and induction, analogy, comparison; 3) and private (special) - logical, comparative-legal, formal-legal, normative-dogmatic; 4) method of interpretation, including the method of problem-theoretical reconstruction. The main results of achieving the goal of the study were proposals on: 1) introduction of the concept of "types and models of legal rationality" into the scientific circulation of jurisprudence; 2) classification of legal rationality into classical and non - classical types and corresponding models-neoclassical (post-classical) and post-non-classical. It should be noted that the post-classical and post-non-classical styles of legal thinking are evolved versions, respectively, of the classical and non-classical types of legal rationality. The basis for the classification of types of scientific rationality in legal science was the anthropological factor-consciousness homo juridicus and methodological tools with which legal consciousness is known. The novelty of the study is that the above classification of epistemological paradigms allows us to look at the law as a multilevel reality, which is simultaneously inherent in the two mechanisms of its Constitution - external and internal. Moreover, the presented criteria-based classification of legal rationality is the basis for the development of legal knowledge.


Author(s):  
D. Vasylenko ◽  
L. Butko

The problem statement. Archival sphere can fit organically into the general concept of digital transformation of Ukraine’s economy. The creation of digital format of archival institutions should be based on identical branch standards and rules for the creation, preserving, accounting, description, using of digital copies in order to ensure a single collaboration algorithm between state, regional and municipal authority levels. The purpose of the research is to analyze the new trends of the management system of the archival sphere from the perspective of regulatory support for the implementation of digitalization tools of Ukrainian archival institutions. The methodology. To resolve the tasks of the research were used traditional complex of common scientific principles (determinism, imaging, unity of opposites) and methods (analysis and synthesis, systematic and structural, questionnaire, content-analysis, observation, statistical). The results. The article analyzes the legal tools as an element of state regulation of digitalization of the Ukrainian archival space. The results of the study were confirmed by a sociological survey on the topic “Do we need to adjust the regulatory basis the archival branch to the digitalization contexts?”. The scientific novelty of the research is to develop the theoretical foundations in the branch of archival sphere management due to context of regulatory support for provision of digitalization issue, including methods of analysis, synthesis and systematization, to generate the problem of introducing the modernizational legislation to manage the digitalization of archival sphere. Conclusions. It is reviewed in the research the influence of the state regulation on the task of systematic development of Ukrainian branch standards and other legal documentation, which is created to regulate the requirements of creation, accounting, preserving, and use of electronic document copies, as well as the collaboration between the archival institutions with stakeholders within a single online platform.


Author(s):  
Canri Chan

This study investigated the effects of government regulations and incentives on the setting of transfer prices. I found significant main effects of both variables on transfer price choices. Transfer pricing is important, particularly for Multinational Corporations (MNCs), because of increased trends toward globalization of business activities and, simultaneously, decentralization. These trends have led to increased pressures for sound internal pricing systems, specifically transfer pricing, in order for organizations to ensure optimal and efficient allocations of organization resources and to provide profit performance measurements (Tang 1992). It has generally been recognized in the literature that in order to maximize after tax cash flows, MNCs shift profits from high to low tax jurisdictions. Governments in some countries, particularly those with high tax rates, are greatly concerned as to whether or not companies attempt to avoid tax liabilities via transfer pricing manipulation, specifically in terms of trying to shift profits to lower tax jurisdictions, and have enacted laws to limit transfer price choice.


2019 ◽  
Vol 7 (4) ◽  
pp. 800-804
Author(s):  
Artur N. Sharmoiants ◽  
Ekaterina P. Klimenko ◽  
Boris V. Zmerzly ◽  
Ekaterina S. Ivashenko ◽  
Alina P. Nikitina

Purpose: Based on the analysis of legal acts and work of other researchers, a historical and legal analysis of the security measures organization was done for trading ports of the Black Sea region of Russia in the 19th and early 20th centuries in this paper. Methodology: This study was based on a dialectical approach to studying the legal phenomena and processes by using general scientific (system, logical, analysis and synthesis) and private scientific methods. Result: The following main components of the legal organization of security measures that are complex in nature: quarantine service; customs; pilot organizations; and port controls. The quarantine and customs authorities included quarantine and, accordingly, border guards. The tasks faced by these bodies were of anti-epidemiological measures nature, i.e. the prevention and detection of offenses with an economic, social and political persuasion. Applications: This research can be used for businessmen and students in economy. Novelty/Originality: In this research, the model of sales ports safety measures in the black sea region of Russia in the 19th and early 20th centuries is presented in a comprehensive and complete manner.


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