МІЖНАРОДНИЙ ОБМІН ІНФОРМАЦІЄЮ ЯК ЗАСІБ ВИЯВЛЕННЯ РИЗИКІВ ТРАНСФЕРТНОГО ЦІНОУТВОРЕННЯ

Abstract

The article considers global trends in the exchange of tax information in order to combat violations in the field of transfer pricing and identify aggressive tax planning schemes. It has been found that the growing role of international groups of companies in the global economy, as well as the use of aggressive tax planning by their representatives to transfer revenues to more taxable jurisdictions (including offshore jurisdictions), undermines the competitiveness of national tax systems. Therefore, recently it has become especially important to establish close cooperation between the tax authorities of the world in the exchange of tax information on the activities of international groups of companies. The international exchange of tax information is considered to be one of the main tools for combating aggressive tax planning. The authors of this study analyzed the current state and key aspects of the development of international exchange of tax information on the example of developments of the Organization for Economic Cooperation and Development and the member states of the European Union. The importance of introducing reporting in terms of countries in Ukraine and the world is substantiated, which in the context of globalization of the world economy will significantly simplify the work of controlling units of tax authorities to identify the risks of transfer pricing, and ensure the prompt exchange of tax information at the international level. The key elements of the implementation of reporting by country (Country-by-Country Reports) are analyzed, as well as the main indicators of tax risk are structured and characterized, which can be identified by analyzing the information provided by taxpayers in such reports. Measures to enhance the effectiveness of identifying and assessing transfer pricing risks based on the analysis of information provided in Country-by-Country Reports are proposed. It is emphasized that to identify transfer pricing risks, in addition to analyzing taxpayers' reporting, it is necessary to take into account all available information sources (macroeconomic statistics, exchange of tax information between countries, customs data, government databases, commercial registers, public information, etc.).