Міжнародні підходи до використання звіту в розрізі країн міжнародної групи компаній як інформаційного джерела оцінки податкових ризиків

Abstract

Introduction. An important step after the country-by-country reports exchange for the first time is the creation of institutional support for the identification and assessment of tax risks based on the data obtained as part of the international exchange of information. Mentioned above actualizes the need for conduction of a complementary analysis of the OECD model legislation in the context of the mentioned issues in order to determine ways of harmonizing it with domestic practice. Problem Statement. Analysis of key provisions of the OECD model recommendations regarding the use of country-by-country reporting as an information source for assessing tax risks. The purpose of the research is to carry out a complementary analysis of the model institutional basis for the use of country-by-country reporting as an information source for assessing tax risks. Methods. In order to achieve the research purpose, the methods of analysis, synthesis, induction, deduction, grouping, description, comparison, theoretical generalization, as well as the abstract-logical method were used. Results. The content of the OECD recommendations “Country-by-Country Reporting: Handbook on Effective Tax Risk Assessment” has been revealed, and basing on the results of the conducted research the authors substantiated the need for harmonization of the domestic practice of identification and assessment of tax risks based on the data obtained as part of the international exchange of information with the model recommendations of the OECD. Particular attention should be paid to the peculiarities of this process during martial law. Conclusions. Basing on the results of the research, the authors proved that after successful passing the stage of implementation of the OECD requirements into national legislation in terms of the form of the country-by-country report and the procedure for its filling it, there is an urgent need for creation by our country institutional support for the identification and assessment of tax risks based on the data obtained within the framework of the international exchange of tax information and its harmonization with the relevant model provisions of the BEPS Action Plan.