Abstract
The article examines the issue of intra-group financing within the activities of multinational corporations, particularly focusing on the provision of financial services between affiliated entities. The essence of credit rating and its impact on intra-group financing are defined. The features of consulting services related to transfer pricing in financial operations are analyzed. It is noted that the use of complex financial instruments in intra-group financing can lead to ambiguous interpretations of tax obligations, creating additional risks for companies. The importance of transfer pricing is substantiated to reflect the true value of goods and services and avoid the risk of reducing the tax base. Special attention is given to the need for consulting support on transfer pricing, which is crucial for mitigating tax risks. The impact of a company’s credit rating on the cost of credit is explored, along with the importance of aligning intra-group transactions with international standards, particularly through the application of the "arm's length" principle to determine the taxable profit of a taxpayer involved in a controlled transaction. The article highlights Ukraine's steps to implement the Base Erosion and Profit Shifting (BEPS) Action Plan, focusing on measures to prevent tax base erosion and profit shifting. The analysis identifies key actions undertaken by Ukraine to introduce international tax control standards for all participants. Measures under the BEPS plan are reviewed, including improvements to interest expense limitations on financial operations, prevention of treaty benefits under inappropriate circumstances, enhancement of permanent establishment taxation rules, better transfer pricing controls, introduction of country-by-country reporting, increased dispute resolution mechanisms, prevention of abuse of double tax treaties, and improved transfer pricing enforcement. Ukraine continues to improve its legislation, particularly regarding the automatic exchange of tax information with other countries.
Published Version
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