Міжнародне співробітництво у сфері протидії ухиленню від сплати податків та запровадження загального стандарту звітності (CRS)

Abstract

Introduction. The strengthening of globalization processes caused significant changes in the international taxation system. The negative consequences of globalization include large-scale tax avoidance and erosion of the tax base. These phenomena caused systematic steps by international organizations in the direction of substantiating the scope of action for the realisation of the process of automatic exchange of information on financial accounts in accordance with the General Reporting Standard and other documents. Ukraine has joined the initiatives of the international community and is consistently implementing measures for their adaptation and implementation. At the same time, there are some limitations in the application of the developed standards, which can be used by unscrupulous taxpayers as a loophole for harmful tax practices. Problem Statement. The scientific basis for the implementation of the BEPS Plan, in particular, the introduction of the process of automatic exchange of information on financial accounts in accordance with the General Reporting Standard. Purpose. Identification of key milestones in the formation and implementation of the BEPS Plan, as well as identification of some limitations and shortcomings in the provisions and procedures of automatic exchange of information on financial accounts, which may lead to abuse, improper actions, violations of confidentiality and security. Methods: analysis and synthesis, comparative analysis, analytical, implementation of a systemic approach to the study of issues Results. The systemic steps of international organizations regarding the implementation of the BEPS Countermeasures Plan and the development of relevant decisions and documents were analyzed. Some limitations in the application of the developed solutions, which can be used by unscrupulous taxpayers as a loophole for the continuation of harmful tax practices, have been identified. The actions of the Ukrainian government regarding joining the international community in the matter of automatic exchange of information on financial accounts are outlined. Conclusions. Therefore, systemic measures for the implementation of the BEPS Countermeasures Plan provide for the formation of a methodology for the application of mechanisms for such countermeasures, in particular principles, directions, tools, procedures and technologies that make impossible or complicate the processes of blurring the tax base and avoiding taxation. For this purpose, key international organizations, in particular the OECD, the Council of Europe, the G20 and the G8, have decided and prepared a number of documents, as well as standards, model and standard agreements to involve national governments in the implementation of joint efforts to counter BEPS, among which a special place is occupied by the Model Competent Authority Agreement (CAA) for automatic exchange of information and Common Reporting Standard. At the same time, when implementing agreements and standards, risks arise due to: avoidance of reporting by some financial institutions and other subjects of legal relations; breach of confidentiality; departure of some countries from general practice and standard procedures, etc. While developing a platform for legal, administrative, financial and economic, technical and technological support for the implementation of BEPS countermeasures, Ukraine should take into account the lessons of negative experience and prevent limitations of the specified standards.