Автоматичний міжнародний обмін податковою інформацією: особливості попередніх умов запровадження в Україні під час воєнного стану

Abstract

Introduction. The main trend in the international tax cooperation is to create institutional conditions to enhance the transparency of the ?nancial ?ows of multinational enterprises for tax administrations and to provide them with relevant information to assess and examine transfer pricing risks. The OECD provides governments with model legislation in the context of this issue, which brings to the fore the issue of its implementation to make the international exchange of tax information work automatically. Problem Statement. To determine the status of implementation of the OECD recommendations on substantial prerequisites for the automatic exchange of international tax information in Ukraine, in particular the peculiarities of their implementation in the martial law period. Purpose. To analyze approaches in the sphere of international exchange of information for tax purposes and to evaluate the status of implementation of substantial preconditions for the introduction of country by country reporting of the international group of companies. Methods. The comparative analysis of the national tax legislation and OECD recommendations regulating the aspects of creation of substantial preconditions for automatic international exchange of tax information was carried out. Results. The list is highlighted and the essence of essential preconditions for countries to obtain access to the international exchange of tax information is revealed. The level of implementation of the stages of introduction of country by country reporting of the international group of companies in Ukraine has been analyzed with the focus on the creation of the appropriate institutional conditions for the implementation of OECD recommendations. According to the results of the research, it has been proved that further steps of formation of the mentioned prerequisites in the country are regulation of con?dentiality aspects of tax information, which is the subject of international automatic exchange, which should correspond to the international approaches with an emphasis on the changes, caused by the introduction of martial law. Conclusions. Having joined the OECD Enhanced Cooperation Programme and committed to implementing the BEPS Action Plan, Ukraine is incorporated into the global tax regulatory framework. After the stage of drafting and approving legislative norms, creation of essential preconditions for obtaining and access to the international exchange of tax information, the next step is to ensure its confidentiality. In this process, it is important to protect the national interests and national security of Ukraine of income and property and prevention of tax evasion.