On the issue of determining the actual tax liabilities in transactions with "high tech" companies

Abstract

The article is devoted to the issues of improving the methodology for determining valid tax liabilities (BOTTOM) in transactions with "high tech" companies. It is noted that due to the increase in the number of "high tech" companies, the question arises not only of the control of their chain of exchange of goods/works/services, but also of determining the rules for calculating the taxes. In this regard, the aim of the article is to develop a methodology for determining the tax liabilities when identifying transactions carried out with "high tech" companies based on an analysis of existing judicial practice. The object of scientific work is a set of socio-economic relations that arise in the process of determining the BOTTOM. The subject of the study is the methodology for determining the actual tax liabilities (BOTTOM) in transactions with "high tech" companies. The research methodology is based on the use of tools and methods for the analysis and synthesis of judicial practice, tabular and graphical methods of data visualization. The scientific novelty of this study lies in the adaptation of the general conceptual methodology for determining the actual tax obligations of Tikhonova A.V. in relation to such a type of tax schemes as a transaction with high tech companies. In the end of the article, transactions with "high tech" companies were classified, the basic method of calculating the BOTTOM for each of the types of transactions considered was determined, the main risk markers of tax evasion schemes in transactions with "high tech" companies were identified, and measures of the tax authority to prove the fact of participation of a "high tech" organization in the transaction were formulated. Thus, the article has meaningful practical significance and will be useful to a wide range of specialists from both tax authorities and consulting organizations.