Institutional provision of preparation of transfer pricing documentation: international experience and directions for development in Ukraine

2021 ◽  
Vol 2021 (12) ◽  
pp. 99-113
Author(s):  
Maryna SVYRYDENKO ◽  
◽  
Maria KUCHERIAVA ◽  
Keyword(s):  
Transfer Pricing ◽  
International Experience

INTERNATIONAL EXPERIENCE IN PROCESSING AND ASSESSMENT BY REGULATORY AUTHORITIES OF TRANSFER PRICING RISKS

2021 ◽  
Vol 296 (4) ◽  
pp. 156-162
Author(s):  
YEVHEN KURILOV ◽  
Keyword(s):  
Risk Assessment ◽  
Risk Management ◽  
Transfer Pricing ◽  
Developed Countries ◽  
International Experience ◽  
Enterprise Group ◽  
Risk Indicators ◽  
Regulatory Authorities ◽  
Pricing Rules ◽  
Pricing Risk

The article analyzes and summarizes the international experience of regulatory authorities in dealing with transfer pricing risks as one of the basic elements of tax control over taxpayers’ compliance with transfer pricing rules. An efficient process for processing and assessing transfer pricing risks helps to ensure quality selection and increase the effectiveness of audits of controlled transactions, increase the efficiency of the use of limited resources, as well as greater tax certainty and reduce the number of unreasonable audits. As a result of the study: international experience was summarized and an indicative process of processing and assessing transfer pricing risks was determined; the main points of the general approach to the issue of transfer pricing risks, which are currently used in practice by the regulatory authorities of economically developed countries, have been identified; the principles of transfer pricing risk management were determined and the importance of carrying out transfer pricing risk assessment processes on an ongoing and systematic basis was indicated; the approaches to organizing the processing and risk assessment of transfer pricing proposed by the specialists of the OECD, JTPF and the UN are considered. Also, the author of the article proposed to supplement this process with a fifth post-assessment stage, which should include the following three steps (13-15): internal inspection and quality control of risk assessment processes based on the results of transfer pricing audits; improving the list of transfer pricing risk indicators and descriptions of their features and identification methods; training and professional development of specialists in the assessment of transfer pricing risks. In addition, attention was drawn to the need for proper documentation of the processing and risk assessment of transfer pricing. The article also concludes that the processes of processing and assessing transfer pricing risks should be integrated into the processes that are carried out within the framework of the functioning of the general risk management system of both the tax authority and any modern large enterprise (group of enterprises).

scholarly journals Country-by-country reporting: international experience of implementation

2021 ◽  
Vol 2021 (6) ◽  
pp. 29-39
Author(s):  
Iryna KRYSHTOPA ◽  
◽  
Larysa NIKOLENKO ◽  
Keyword(s):  
Income Distribution ◽  
Tax Evasion ◽  
Information Exchange ◽  
Multinational Enterprises ◽  
Transfer Pricing ◽  
International Experience ◽  
Country Report ◽  
Financial Flows ◽  
National Legislation ◽  
International Group

Considering the tasks set for Ukraine in frames of combating tax evasion of multinational enterprises, it is extremely important to bring the provisions of national legislation in line with international rules of tax administration. This primarily concerns the creation of institutional conditions in order to increase the financial flows transparency of multinational enterprises for tax administrations and enable them to obtain necessary information for identifying and assessing transfer pricing risks.Nowadays, more than 100 countries prepare a country-by-country report of an international group of companies, which discloses data on activities of certain enterprises in accordance with the requirements of national legislation and the unified standard of country-by-country reporting, approved by the OECD [1]. However, the analysis of domestic practice of reporting by countries of international group of companies, as well as the study of other regulations, which application allows metropolitan countries to ensure the transparent level of taxation of their multinational corporations, indicates the need for further improvement of domestic mechanisms for counteracting tax base erosion and exchange of information obtained in the framework of international exchange. This fact actualizes a chosen research topic. It is revealed that information disclosed in country-by-country reports gives the possibility for tax administrations to assess high risks of transfer pricing. In turn, the development of the mechanism for ensuring confidentiality and appropriate use of such reports will oblige taxpayers to careful adhere to transfer pricing rules and mandatory tax information exchange. The investigation of international experience in frames of implementation of uniform standards for the disclosure of information on income distribution and tax payments suggests the importance of country-by-country reporting. And identification of main trends in the field of international initiatives on issues of disclosure of income distribution information by groups of enterprises brings Ukraine closer to the consistent implemen­tation of this approach in practice of international groups of companies.

On Mechanisms of Realization of the Public Procurement of Construction Works (The Case of Road Const ruction)

2003 ◽  
pp. 68-80
Author(s):  
A. Dementiev ◽  
A. Zolotareva ◽  
A. Reus
Keyword(s):  
Public Procurement ◽  
Road Construction ◽  
International Experience ◽  
The Public ◽  
Government Purchases ◽  
Efficiency And Effectiveness ◽  
Construction Works ◽  
Budget Expenditure

The most important measures stimulating the increase of efficiency and effectiveness of budget expenditures on road construction are the improvement of pricing mechanisms and increasing efficiency of the procedures of government purchases of goods, works and services. The paper includes the analysis of main problems that arise in the process of government purchases and construction pricing with the reference to budget expenditure on road construction. It includes the review and analysis of international experience and possible measures of increasing the efficiency and effectiveness of government purchases and (road) construction pricing in Russia.

Forestry: The Mechanisms of the Accordance of the Rights of User Analysis

2006 ◽  
pp. 57-70 ◽  
Author(s):  
A. Manakov
Keyword(s):  
International Experience ◽  
Auction Design

The author considers the ways in which the rights of user of the forestry in Russia are granted. The article analyzes the international experience of forest auctions and describes the main problems of the auction design.

Perspectives of Reforming the System of Interbudget Relations in Russia (in the Light of the International Experience)

2006 ◽  
pp. 112-127 ◽  
Author(s):  
V. Nazarov
Keyword(s):  
Social Welfare ◽  
Intergovernmental Relations ◽  
International Experience ◽  
Point Of View ◽  
Short History ◽  
History Of

The attempts to reconstruct the instruments of interbudget relations take place in all federations. In Russia such attempts are especially popular due to the short history of intergovernmental relations. Thus the review of the ¬international experience of managing interbudget relations to provide economic and social welfare can be useful for present-day Russia. The author develops models of intergovernmental relations from the point of view of making decisions about budget authorities’ distribution. The models that can be better applied in the Russian case are demonstrated.

Introduction of Full Convertibility of National Currency: Problems of Theory and Practice

2005 ◽  
pp. 61-71 ◽  
Author(s):  
A. Navoi
Keyword(s):  
Transition Economies ◽  
International Experience ◽  
Theory And Practice ◽  
National Currency ◽  
Russian Economy ◽  
Advanced Economies ◽  
Additional Income

The article is devoted to actual questions of introducing convertibility of the ruble. The structure and definitions of convertibility are considered. On the basis of the international experience the economic essence of convertibility as a source of additional income of the states-emissioners is revealed. The sequence of stages of convertibility in advanced economies is presented, basic problems of introducing convertibility in developing as well as in transition economies are studied. The experience of transition to convertibility of the ruble and corresponding consequences for the Russian economy are analyzed.

Sign in / Sign up

Export Citation Format

Share Document