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№ 11/2022

№ 11/2022

Fìnansi Ukr. 2022 (11): 35–48
https://doi.org/10.33763/finukr2022.11.035

SCIENTIFIC CONFERENCES

KRYSHTOPA Iryna 1, OLIINYK Yana 2, BABII Lesia 3

1SHEE “Kyiv National Economic University named after Vadym Hetman”
OrcID ID : https://orcid.org/0000-0003-1759-6472
2SESE “The Academy of Financial Management”
OrcID ID : https://orcid.org/0000-0001-5895-282X
3Kyiv National Economic University named after Vadym Hetman
OrcID ID : https://orcid.org/0000-0002-6516-0377


International experience in identification of tax risks according to the data obtained within the framework of international exchange of information


Introduction. Most countries of the world are involved in the global system of exchange of tax information within the framework of the Action Plan in order to fight tax base erosion and profit shifting abroad (BEPS). This brings to the fore the problems of studying the best practices of implementing OECD recommendations into national legislation.
Problem Statement. According to the recommendations of the OECD, one of the main goals, which achievement is critically important for the content of the information contained in the three-level transfer pricing documentation (including a country-by-country report for an international group of companies), defines the need for ensuring the ability to conduct a transfer pricing risk assessment and audit. In particular, it is noted that for such an assessment it is important to provide tax administrations with access to the information they need to assess the risk of transfer pricing. The norms that implement the BEPS Action Plan have been introduced into the national legislation, and the corresponding normative and legal support has been formed. Currently, the issue of effective identification and assessment of risks based on data obtained within the framework of international information exchange has arisen. This fact actualizes the study of best practices in this area.
Purpose. The purpose of the research is to conduct a complementary analysis of international experience of implementation of the OECD model approach to identification of tax risks based on data obtained within the framework of international information exchange into the work of foreign countries tax authorities.
Methods. In order to achieve the purpose, the authors used methods of analysis, synthesis, induction, deduction, comparison, theoretical generalization as well as abstract and logical method.
Results. The approaches of the world's leading countries (namely, Australia, Brazil, Canada, Chile, India, the Netherlands, Spain) to the implementation of the model document “Country-by-Country Reporting: Handbook on Effective Tax Risk Assessment” into the work of their tax authorities were analyzed.
Conclusions. According to the results of the research the authors generalized the peculiarities of implementation process of the OECD model approach to identification of tax risks based on the data of country-by-country reports for an international group of companies into the work of tax authorities of foreign countries. The general trends have been outlined as well. In addition, the need for creation of national institutional support for the identification and assessment of tax risks based on data obtained as part of the international exchange of tax information has been substantiated.

Keywords:tax system, BEPS action plan, transfer pricing, fight against erosion of the tax base, international exchange of tax information, international group of companies, country-by-country report for an international group of companies, transfer pricing risks, assessment of tax risks

JEL: Н29


Kryshtopa I. . International experience in identification of tax risks according to the data obtained within the framework of international exchange of information / I. Kryshtopa, Y. Oliinyk, L. Babii // Фінанси України. - 2022. - № 11. - C. 35-48.

Article original in Ukrainian (pp. 35 - 48) DownloadDownloads :73
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