КОНСОЛИДИРОВАННОЕ НАЛОГООБЛОЖЕНИЕ: ЗАРУБЕЖНАЯ ПРАКТИКА

Abstract

Consolidation involves combining several interconnected organizations into a single taxpayer, however, it is worth noting that consolidation is possible for only certain taxes - most often corporate income tax, value added tax, and less often excise taxes and other taxes. Such a regime is aimed at unifying tax administration and changing the distribution of tax revenues from their activities between territorial entities. Note that each country has its own model of tax consolidation, which differs in one way or another from the models of other countries. Many countries allow groups of companies to calculate tax liabilities as a combined taxpayer, or develop special rules for group members, which, in principle, can have the same result. Tax regulation can also be carried out through transfer prices. However, despite the country differences, the mechanism of action of consolidated taxation always depends on the company's status in the group, which is the basis of the method of tax consolidation. The purpose of introducing tax regimes for related companies in all countries is the same-joint taxation of all group members. At the same time, the methods used to achieve this goal and establish a special tax procedure are different. The article is devoted to the review of the world practice of taxation of consolidated taxpayers. The author paid special attention to the international practice of submission of claims to the equity of the parent company in the equity of subsidiaries, the method of electing the mode of participation of non-resident companies and taxes for the calculation and payment of which allowed the Association. The study of foreign practice of combining companies into consolidated groups for tax purposes revealed similarities and differences in the regimes in force in a number of foreign countries.