THE CONCEPT OF CORPORATE REFORM INCOME TAXATION IN UKRAINE

The article examines the feasibility and relevance of reforming corporate income taxation in Ukraine. We have scrutinized scientific researches of domestic and foreign scientists. The low fiscal efficiency of corporate income tax has been investigated and a stable relationship has been detected between the level of tax payment and a set of additional factors, namely the level of corporate management, the form of ownership and public attention. The high weight of the payment of income tax in the overall structure of the top-30 enterprises of Ukraine for the payment of taxes was noted. The international experience of corporate income taxation is analyzed and summarized. The necessity of replacing the income tax with another type of corporate income taxation has been substantiated. Systemic problems of the effectiveness of the existing models of corporate income taxation in the world are noted. The negative impact of low-tax on the functioning of tax systems in a lot of countries and the creation of the effect of uneven tax burden is emphasized. Information on the practical experience of introducing a tax on withdrawn capital in the foreign countries has been systematized. The low efficiency of that concept and the inexpediency of using this concept in the modern domestic conditions have been investigated. The possibility of replacing the value added tax has been assessed and the critical dependence of the budget incomes on the tax has been established. Concept of reforming corporate income taxation was developed and substantiated by introducing 1% turnover tax in addition to value added tax and the complete abolition of income tax. The volume of tax receipts for 2010—2019 has been estimated in the case of the introduction of author's concept of corporate taxation of income instead of current taxation system. The positive consequences for Ukrainian economy have been evaluated and systematized. Strong need to form a new tax culture and philosophy of interaction between representatives of tax authorities and business was emphasized. Keywords: corporate income taxation, corporate income tax, tax on withdrawn capital, turnover tax. JEL Classіfіcatіon H25 Formulas: 0; fig.: 0; tabl.: 3; bibl.: 19.

Tributação de Rendimentos Empresariais, Criação de Valor, Evasão Fiscal – Uma Visão Geral / Corporate Income Taxation, Value Creation, Tax Evasion - An Overview

A evolução mundial das economias bem como as recorrentes e crescentes necessidades de financiamento dos Estados vão levando o legislador a procurar cada vez mais adaptar a forma de suprir essas necessidades.Pretendemos primeiramente de forma global apresentar o estado atual dos principais impostos sobre os rendimentos das empresas portuguesas, bem como uma visão geral e teórica da sua agregação, na ótica de carga fiscal efetiva, expondo o conceito da Curva de Laffer (Laffer, 2004).Será também exposta a relevância da problemática da economia paralela e evasão fiscal, como uma abordagem global das suas implicações, medidas de combate e da relação com a evolução da carga fiscal.Perspetivaremos ainda uma hipotética alteração da base de incidência da tributação dos rendimentos empresariais, sendo por ora o resultado gerado, ainda que após ser sujeito a algumas correções, para em lugar deste, tributar efetivamente a criação empresarial de valor.

Foreign experience in income taxation of companies

The subject of this research is the rules of corporate income taxation foreign countries existing in foreign countries, the experience of implementation of which is valuable for further development of the Russian legislation. The current state of tax systems is viewed from the perspective of implementation of the baisc tax functions: fiscal and regulatory. The importance of corporate profit taxation in formation of the income base of the budgets of the budgetary system of the Russian Federation justifies special attention to the existing mechanisms for distinguishing tax revenues between budgets of bot different levels and same level. In the context of state regulation of the economy, analysis is conducted on the tax incentive instruments and preferential tax conditions intended for stimulating innovative activity of the companies. The scientific novelty lies in summarizing the experience of foreign countries in corporate income taxation, determining the leading  practices, and formulating recommendations for their implementation in Russia. The conducted research reveals the trends in reforming tax legislation of the developed countries aimed at stimulation of entrepreneurial activity. Sustained reduction in corporate income tax rates, shift away from progressive scale, and implementation of new tax incentives contribute to lowering of fiscal burden on businesses and create favorable conditions for the economic development. The author develops recommendations for the improvement of corporate profit taxation in the Russian Federation: 1) For increasing the validity of division of tax revenues between regional budgets, it is suggested to change the procedure for calculating the tax payable by separate banks units. In calculation of the share of taxable profit for each bank unit, it is recommended to take into account labor costs, amount of loans issued and deposits raised. 2) The comparative analysis of the Russian and foreign experience of tax incentives demonstrated the shortage of instruments intended for commercialization of innovations in the Russian Federation, which substantiates the need for implementation of preferential taxation of income from use of the objects of intellectual property.

Assessment of the international competitiveness of the corporate income tax of Ukraine

The article is devoted to assessing the international competitiveness of the corporate income tax system based on the approach of the US Tax Foundation, which develops International Tax Competitiveness Index of the corporate income tax (ICI) and takes into account the level of income tax rates, cost recovery, tax incentives and complexity of tax law. According to the analysis of the international ranking of OECD countries, Estonia, Latvia, Lithuania, and Hungary had the highest ICIs in 2019-2020. The main factors that have had a positive effect on their competitiveness are the low top marginal income tax rate, unlimited loss carryback and carryforward, no restrictions on the list of assets subject to depreciation, as well as the use of accelerated depreciation, which allows companies to compensate for a larger share of the initial value of assets, LIFO inventory or at least inventory by the weighted average cost method, no Patent Box; no tax credit for R&D, and low corporate income tax complexity. The calculation of the ICI for Ukraine, based on the approbation of the methodological approach of the Tax Foundation, found that in 2019-2020 Ukraine with a total score of 55.07 took 24th place out of 35 OECD countries. The author characterizes the main components of Ukrainian corporate income taxation in terms of their impact on international competitiveness; in addition, ways to increase ICI are substantiated.

CURRENT STATE OF CORPORATE INCOME TAXATION SYSTEM IN UKRAINE

Taxes are used as a way of government influence on social production, its dynamics and structure, and are also a source of government revenue. To the greatest extent, this applies to corporate income tax, since it is one of the most important sources of budget revenue. Difficult political and economic conditions, instability and complexity of domestic legislation, a significant tax burden on business highlight the need to study the peculiarities of corporate income taxation not only as a powerful fiscal tool, but also in terms of its regulatory functions. In Ukraine, the possibilities of using corporate income tax as a regulatory factor are somewhat limited by its large budgetary value, so there is a need to study also a foreign experience of corporate income taxation in order to find the best ways for our country to improve the collection and administration of corporate income tax. To stimulate entrepreneurial activity, ensuring its stable development, it is necessary to create an optimal effective tax system that would provide stable revenues to the state budget, without burdening entrepreneurs. This issue is extremely acute, because the corporate income tax can be used as an effective tool for balanced dynamic economic growth on the basis of innovative development, and as a reliable source of state budget revenues. This article defines theoretical questions concerning the economic essence and place of the corporate profit tax in the taxation system. Determined main reasons for the fluctuations of revenues from corporate income tax in the budget of Ukraine, namely: the loss of income tax of the dominant fiscal role in the formation of tax revenues of Ukraine is due to lower rates and changes in the procedure for determining the object of taxation, as well as general negative trends in economic development of Ukraine. The main areas of improvement of corporate income taxation mechanism in Ukraine at the present stage of economy development are investigated. Conclusions are drawn about introducing a progressive system of corporate income taxation, harmonization of accounting and tax legislation on the calculation of corporate income tax, reviewing the list of tax incentives and using the accelerated depreciation method that reduces the tax base.

HUNGARIAN IFRS IMPLEMENTATION FROM TAX PERSPECTIVE

The influence of corporate income taxation on financial statements presented on a domestic accounting standards basis differ by countries in a wide range. Corporate income taxation in Hungary has a strong connection to the Hungarian Accounting Act. From 2016 it is prescribed or allowed for specific companies to present their financial statements on IFRS basis. The transition represented not only a challenge in the accounting system of the companies, but the state had to face new tasks because the taxation of IFRS companies had to meet the tax principle of horizontal equity and ensure the proper tax revenue. Research data arise from financial statements of Hungarian companies listed on the Budapest Stock Exchange. The average effective tax rate of Hungarian listed companies decreased after the transition. Temporary tax rules for IFRS companies were applied to reach the tax level of the companies that prepare their financial statements following the Hungarian Accounting Law. Authors compare the results with empirical findings of other European countries.

CHALLENGES TO THE TAXATION OF THE DIGITAL ECONOMY

Globalization and digitalization have led to the emergence of new business models based on the remote provision of services. Digital companies have access to consumers in countries all over the world without physical presence in these countries. As a result, their profits remain untaxed. There is an increasing awareness that the existing legislative provisions for corporate income taxation that date back to the 1920s need to be modernized. Currently, the possibilities for taxation of digital businesses are discussed in the context of the OECD and EU. However, progress is slow due to the different views and interests of the countries involved. Therefore, several countries have planned or already introduced digital taxes unilaterally. The purpose of the paper is to explore the specifics of digital taxes and to analyze the possibilities and challenges to their broader application. The paper is organized as follows: the first part outlines the most important digital business models; the second part dwells on the digital taxes that are implemented in several countries; the third part presents the projects for international coordination of these taxes; and the fourth part concludes.