scholarly journals THE INFLUENCE OF BEPS INITIATIVES ON FORENSIC EXPERTISE CONCERNING THE ISSUE OF TRANSFER PRICING

2020 ◽  
pp. 575-584
Author(s):  
I. Hrinenko ◽  
Yu. Hrinenko
Keyword(s):  
Tax Evasion ◽  
Transfer Pricing ◽  
Action Plan ◽  
Competent Authority ◽  
The State ◽  
Economic Activities ◽  
Profit Shifting ◽  
State Budget ◽  
Foreign Companies ◽  
Mutual Agreement

Ukraine has joined the BEPS (Base Erosion and Profit Shifting) action plan to combat tax evasion and increase tax transparency around the world. In other words, the state must respond appropriately to ensure the taxation of profits in the country where the taxpayer is engaged in economic activities. Such actions will reduce the transfer of capital to jurisdictions with low levels of taxation, which in turn will help to increase the revenues of the state budget. With regard to the implementation of the provisions of the BEPS Action Plan, Law No. 465-IX introduced the concept of taxation of profits of controlled foreign companies at the level of the controlling entity; introduced a three-tier documentation structure for international groups of companies, which includes transfer pricing documentation (local file), global documentation (master file) and country-by-country reporting; implements provisions 8 to 10 of the BEPS plan to control the distribution of functions, risks and intangible assets within a group of companies, improve the rules for commodity transactions by eliminating the restriction on the use of stock quotes of certain exchanges and allowing the use of quotations for such commodities; the procedure for carrying out the mutual agreement procedure has been determined, which provides for the mechanism of submitting the application for the consideration of the case under the mutual agreement procedure, the requirements for such application, the procedure for the action of the competent authority, etc .; introduced the concept of taxation of dividends equal to dividends, which provides for adjustments to the methodology and procedures envisaged to control transfer pricing when conducting transactions with non-residents.

scholarly journals Laundering Black Money by Means of Offshore Zones: The Negative Impact and Ways to Resolve

2021 ◽  
Vol 8 (523) ◽  
pp. 140-150
Author(s):  
O. T. Zamaslo ◽  
◽  
D. A. Kozak ◽  
Keyword(s):  
National Economy ◽  
Tax Evasion ◽  
Negative Impact ◽  
Action Plan ◽  
International Standards ◽  
Key Factors ◽  
Profit Shifting ◽  
State Budget ◽  
Business Entities ◽  
The Impact

The article is aimed at examining the problem of laundering black money in the offshore jurisdictions. Attention is paid to the key factors that attract economic entities regarding business registration in offshore zones. The impact of the tax burden on the process of moving profits to offshore jurisdictions is considered. The volumes of losses of the State Budget of Ukraine related to tax evasion of the funds placed on the accounts of offshore companies have been studied. The most typical schemes of laundering black money in offshore zones are presented, as well as a number of stages that form the process of laundering are highlighted. Emphasis is placed on round tripping investment as a key mechanism for returning foreign funds to a resident in the form of foreign direct investment, the main factors in the use of round trip transactions by Ukrainian business entities are allocated. Attention is drawn to the percentage of countries, which are the largest investors in Ukraine. It is determined that the use of offshore schemes by Ukrainian businesses contributes to the growth of the shadowing of the national economy and causes a direct negative impact on Ukrainian financial security, which is confirmed by the results of the National Risk Assessment 2019. Emphasis is placed on the OECD / G20 Base Erosion and Profit Shifting (BEPS) initiative to prevent money laundering offshore, and Ukraine’s key measures to implement relevant international standards are specified. Prospects for further research in this direction are to identify measures directed towards deoffshorization of the national economy, including through the implementation of the BEPS 2.0 Action Plan.

scholarly journals Implementation of international recommendations for application of a three-tiered approach to transfer pricing documentation in Ukraine

2020 ◽  
Vol 2020 (9) ◽  
pp. 95-109
Author(s):  
Ljudmyla LOVINSKA ◽  
◽  
Yana OLIYNYK ◽  
Maria KUCHERIAVA ◽  
◽  
...  
Keyword(s):  
Information Asymmetry ◽  
Transfer Pricing ◽  
Action Plan ◽  
The State ◽  
Profit Shifting ◽  
Tax Base ◽  
The World ◽  
Level Model ◽  
The Government

The article considers challenges and consequences of introducing a three-level model of transfer pricing documentation in Ukraine. The purpose of study is to assess the state of regulatory support for implementation of Step 13 of the BEPS Action Plan and to identify institutional measures for further implementation of three-tiered documentation on transfer pricing, taking into account the requirements of the Organization for Economic Co-operation and Development (OECD). The authors analyzed the state of accession of countries all over the world to the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting, in order to counteract the erosion of the tax base and the withdrawal of profits from taxation of the OECD, ratified by the Law of Ukraine dated 28.02.2019 No 2692-VIII. Analysis of national legislation to take into account the requirements of the BEPS Action Plan and the experience of cooperation of the Government of Ukraine with international tax organizations allowed to scientifically substantiate the directions of improvement of national regulations on tax issues and to determine methodology for application of innovative reporting form in the context of further implementation of BEPS Action Plan. It is identified that implementation of a three-tiered reporting model for transfer pricing in Ukraine is at the beginning of the development, in particular legislation. The authors emphasize the importance of counteracting information asymmetry by ensuring the unification of terminology and quality of the database for innovative reporting preparation, in particular, for global documentation on transfer pricing, transfer pricing documentation and Country-by-Country reporting of multinational entities. Within the study it was proved that the organization of the reporting process at all levels of the Three-Level Model of transfer pricing documentation (hereinafter the Three-Level Model) should be aimed at preparing reports that contain reliable information with the maximum exclusion of duplication.

ENSURING EFFECTIVE ACTIVITY OF TAX ADMINISTRATION -AN IMPORTANT FACTOR FOR INCREASING TAX ACCOUNTABILITY

2020 ◽  
Vol 8 (3) ◽  
pp. 40-48
Author(s):  
Uguloy Berdiyeva ◽  
Keyword(s):  
Tax Evasion ◽  
The State ◽  
Tax Administration ◽  
Tax Collection ◽  
State Budget ◽  
Effective Activity

The article discusses the issues of increasing the level of tax collection on the basis of improving tax administration, ensuring the full payment of taxes and fees to the state budget, reducing the likelihood of tax evasion.

Effectiveness of Tax Policy of Ukraine: Evidence and Economy Implications

2020 ◽  
pp. 124-131
Author(s):  
Olena P. Slavkova ◽  
Oksana I Zhilinska ◽  
Maksym Palienko
Keyword(s):  
Economic Development ◽  
Tax Evasion ◽  
Tax Policy ◽  
The State ◽  
State Budget ◽  
Advantages And Disadvantages ◽  
State Tax ◽  
State And Local ◽  
Tax Payments

The article deals with the peculiarities of the formation and implementation of tax policy in the country. The analysis of change of tax receipts to the state and local budgets is carried out. The role of tax payments in the economic development of the country is determined. The efficiency of the state tax policy in Ukraine is analyzed, its advantages and disadvantages are determined. The important role of tax payments in stimulating economic and social development is substantiated. The analysis of the elasticity of change of indicators of economic development of the country from the change of volume of tax receipts to the budget is carried out. The necessity of improving the existing policy of establishing, accrual, payment, and distribution of tax revenues as one of the most promising areas to stimulate economic growth is concluded. Keywords: tax policy, revenues, tax evasion, state budget, elasticity, economic development

scholarly journals Some features of the fight against tax evasion

2020 ◽  
pp. 72-78
Author(s):  
Nailya Shevko ◽  
Gulnara Hadiullina
Keyword(s):  
Public Sector ◽  
Research Methods ◽  
Tax Evasion ◽  
Tax Policy ◽  
The State ◽  
Theoretical Research ◽  
State Budget ◽  
The Public ◽  
Fair Competition

Unfortunately, tax evasion still exists today. As a result, there is insufficient funding for the public sector of the economy due to a reduction in revenue to the state budget. At the same time, there is a violation of the rules of fair competition. In order to ensure that the fight against tax and tax evasion is as effective as possible, it is important to determine the causes and methods of avoiding taxation, examine the current tax policy, and identify incentive leverage of taxes to replenish the revenue side of the budget. In the course of writing the work, empirical and theoretical research methods were applied, and legitimate ways to derive income from the shadows were identified.

scholarly journals The Investment Attractiveness of Economic Activities in the Regions of Ukraine

2021 ◽  
Vol 5 (520) ◽  
pp. 169-174
Author(s):  
O. V. Nechyporuk ◽  
Keyword(s):  
Regression Analysis ◽  
Economic Activity ◽  
Public Investment ◽  
Analysis Data ◽  
The State ◽  
Economic Activities ◽  
State Budget ◽  
Correlation And Regression Analysis ◽  
Methodical Approach ◽  
The Impact

The article is aimed at studying the investment attractiveness of types of economic activity in the regions of Ukraine, determining the impact of factor values (of types of economic activity) on the volume of products sold. As a result of the study, a methodical approach to the analysis and determination of investment attractiveness of types of economic activity in the regions of Ukraine is developed; the influence of factor values (of types of economic activity) on the volume of products sold is determined, the main ones are distinguished by means of correlation analysis and the significance of the selected factors of influence is checked using regression analysis. For the analysis, data was formed on the basis of official data of the State Statistics Service of Ukraine and the Ministry of Economy of Ukraine. To obtain more accurate summary results, the data was normalized in order to convert the values of signs in the input vector to a certain specified range. After the normalization, summary data for correlation and regression analysis were computed. On the basis of the carried out analysis, the economic-mathematical models of influence of investment instruments of the State budget on types of economic activity and a model of influence of investment instruments of foreign direct investment on types of economic activity in the regions of Ukraine were built. The investment attractiveness of certain regions for public investment and for foreign investments is substantiated. Prospects for further research in this direction are the analysis of the impact of other factors on the investment attractiveness of a particular region and Ukraine in general.

scholarly journals GLOBAL BUSINESS NETWORK: OFF-SHORE MODEL’S DIVERSIFICATION AND IMPACT

2020 ◽  
Vol 5 (2) ◽  
pp. 20-29
Author(s):  
Yaroslava Stoliarchuk ◽  
Denys Ilnytskyy ◽  
Glib Turolev
Keyword(s):  
Financial Management ◽  
Transfer Pricing ◽  
Developed Countries ◽  
Economic Activities ◽  
Profit Shifting ◽  
Global Business ◽  
Goods And Services ◽  
Objective Reduction ◽  
Real Purchasing ◽  
National Economies

Modern literature lacks systematization and assessment of impact of network of international corporations and their off-shore models on development of national economies in post-industrial times. There is variety of tools besides well-known multinational corporate accounting policies and strategies of MNCs that provide mechanism for the management of transaction costs in reporting period, thus reducing the amount of taxable profit due to application of the method of accelerated depreciation and channels of tax deferrals, which allow to reduce corporate tax payments owing to the objective reduction of real purchasing power of money over time. The purpose of the article is to propose in-depth systematization of balanced pros and cons for further development of national FDI policies aimed at network of MNCs. The paper utilizes a compound methodology of review and systematization to calculate overall impact of offshoring that exceeds 1% of global GDP. While modern financial and economic activities of MNC’s distinguish both internal and external offshoring, the paper focuses upon endogenous one. The key attention is on dominant ones – tax inversion phenomenon is known as base erosion and profit shifting, tax planning strategies, international debt shifting, models of tax treaty shopping, tax deferral, tax hybrids, strategic transfer pricing tools. In business and financial management MNCs resort to the development of extremely complex network structures of parent and subsidiary companies in order to increase international competitive advantages. MNCs make special efforts to recruit staff capable of effectively performing key functions in the field of corporate offshoring. We find huge regional asymmetries in MNCs impact on development of national economies. On one hand, a number of highly profitable corporations pay almost zero tax in favour of their countries of registration; on the other, MNCs create jobs, markets, volumes and asymmetries of geographical structure of differences in the value of goods and services supplied through international trade between developing and developed countries due to enormous scale of business offshoring.

scholarly journals Study of Opportunities on Sharia-based Securities Instruments to Enhance the Economic Development in Indonesia

2019 ◽  
Vol 13 (2) ◽  
pp. 169-181
Author(s):  
Arif Effendi
Keyword(s):  
Economic Development ◽  
Public Housing ◽  
Social System ◽  
Manufacturing Industry ◽  
Negative Impact ◽  
The State ◽  
Human Beings ◽  
Economic Activities ◽  
State Budget ◽  
The Social

The purpose of Sharia Economics is to realize the goodness, prosperity, and prosperity of human beings, especially in the economic field. Islamic Sharia prohibits the practice of usury in all its economic activities, because of its negative impact on the social system and the economy of society. Article 1 of Law Number 19 Year 2008 stipulates that the State Sharia Securities or Sukuk, is state securities issued under sharia principles, so It must be free from various elements of the ban, such as usury, maysir, and gharar. Sukuk issuance aims to finance the State Budget, including financing the construction of projects, such as infrastructure projects in the energy sector, telecommunications, transportation, agriculture, manufacturing industry, and public housing. Therefore, the participation of Muslims as the majority in Indonesia are needed to become the investor. The method used in this article is librarian research. In describing, analyzing, and evaluating, we used the regulation concerning with state sharia securities in Indonesia such as Law Number 19 year 2008 and Fatwa of National Sharia Council No: 69/DSN-MUI/VI/2008 concerning State Sharia Securities. Participating as an investor in the State Sharia Securities means participating in developing the country

scholarly journals Methodological Support for Separate Accounting   of the Performance of State Defense contractors (SDc)

2020 ◽  
Vol 6 (6) ◽  
pp. 67-75
Author(s):  
N. T. Labyntsev ◽  
P. V. Kolesnik
Keyword(s):  
The State ◽  
Economic Activities ◽  
Regulatory Requirements ◽  
State Budget ◽  
Defense Contractors ◽  
The Russian Federation ◽  
Methodological Approaches ◽  
Definition Of ◽  
State Defense

Currently, the Russian Federation invests heavily in the production of products under the state defense order (hereinafter — SDO). The head executors and executors of the state budget are obliged to ensure separate accounting of the results of financial and economic activities for each state contract. The article is devoted to the development of methodological support for separate accounting of performance at enterprises which are the executors of the state budget. The research methodology is an analysis of existing methodological approaches to separate accounting of financial results of the SDO and the construction of the author’s own methodology on their basis. The article offers recommendations on the organization and methodology of separate accounting of the results of financial and economic activity by the organizations-executors of the SDO. The author’s definition of the term “separate accounting of the results of financial and economic activities in SDO” is given. The form of the register of accounting for grouping of the actual costs for execution of the SDO is developed. The developed recommendations for management job order costing accounting, clearance accounting, classification of costs by types, and the formation of registers of analytical accounting will allow the organizations-executors of the SDO to keep separate records in accordance with the regulatory requirements and to obtain information on the financial results of each contract at any given time.

scholarly journals The results of implementation of european requirements in management of transfer pricing audit (experience of Ukraine)

2020 ◽  
Vol 11 (9) ◽  
pp. 2417
Author(s):  
Valeriia Fesenko ◽  
Olena Vakulchyk ◽  
Olexandr Guba ◽  
Serhii Ostapchuk ◽  
Iryna Babich
Keyword(s):  
Control System ◽  
Cost Effectiveness ◽  
Economic Activity ◽  
Transfer Pricing ◽  
Tax Planning ◽  
The State ◽  
Income Taxation ◽  
State Control ◽  
Profit Shifting ◽  
Current Trends

Since 2017 four of fifteen steps of the BEPS plan (base erosion and profit shifting) have been introduced in Ukraine to resist various areas of aggressive tax planning. The implementation of the BEPS plan is primarily made through frame working a transfer pricing control system in Ukraine, which aims to reduce illegal tax sheltering through foreign economic transactions with interdependent or interested parties as well as through transactions with contractors that are registered or make business in low-tax jurisdictions. The purpose of this study is to evaluate the results of implementation of European requirements in the system of audit of foreign economic activity in Ukraine. The study is based on data from the State Statistics Committee of Ukraine, the State Fiscal Service of Ukraine for 2015-2019.The article identifies the amounts of Ukrainian exports (imports) to (from) low-tax jurisdictions, analyzes the controlled exports and imports by geographical segment. The study presents evidence of the use of transfer pricing mechanisms by Ukrainian companies to optimize income taxation, which is contrary to the interests of the state. Therefore, a special need consists in improvement of the state control over operations of the foreign economic activity. The changes and current trends in foreign economic operations during the implementation of transfer pricing controls since 2013 in accordance with the BEPS plan were examined. This study proves that immediately after expanding the list of low tax jurisdictions, there has been a significant fall in the volume of controlled exports and imports, which we regard as a loss of cost-effectiveness of trade operations through low tax jurisdictions due to increased controls and enlarged list of territories, transactions through which are under strict control.

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