CbC-REPORTING IN TAX ADMINISTRATION

Abstract

Background. Countering the erosion of the tax base through the use of transfer pricing (TP) is an important element of tax policy. Ukraine is implementing three-level TP reporting and the procedure of automatic exchange of tax information. The analysis of recent research and publications has showedthat research on the use of data obtained in the exchange of tax information procedure under the CbC standard is relevant and controversial. The aim of the articleis to investigate the conditions for the introduction of automatic information exchange in Ukraine and provide recommendations for the practical use of the obtained data for tax control purposes. Results. An analysis of the structure of three-level TP reporting and the conditions of its first submission in Ukraine was performed. The procedure of automatic exchange of tax information according to the CbCR standard is considered. Based on the results of this study, a set of proposals for the use of CbC reporting data for tax administration purposes has been developed. The implementation of these proposals will help strengthen tax control and administration. Conclusion. The information received under CbCR-standard is intended for comprehensive analysis and risk identification by tax administrations and cannot be an alternative to tax audits or investigations. The obtained results can be used to build the business processes on CbC information application by the tax authorities. Further research in this direction should focus on the development of recommendations for the business process on the automatic exchange of information according to the CbCR standard establishment and the further use of the data obtained under this exchange by the tax administration.