Changes in the Value Added Tax as the Tool against the Global Crisis

Dugová, Alena

doi:10.18267/j.efaj.108

Cited by 2 publications

(2 citation statements)

References 8 publications

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“…Governments levy taxes on all constituents of value added through taxation of wages, profits, and value added itself. The focus of tax legislation shifts from direct taxes to indirect ones, at least in the EU27 (Dugová, 2013). Tax is, at least partially, beyond any doubt a price for public services (Hettich, 2005, p. 420).…”

Section: The Allocation Of Upside and Downside Risks Among Stakeholdersmentioning

confidence: 99%

Судова Економічна Експертиза З Питань Трансфертного Ціноутворення

Фоміна¹,

Shushakova²

2024

ЕУ

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The integration of national economies and markets, the ability of large corporations to conduct international business, the development of the digital sector of the economy contribute to global trends in the globalization of the international taxation system. The exchange of tax information and the conduct of joint tax audits by the tax authorities necessitate the unification of approaches to transfer pricing by transnational companies. The intensification of tax audits by tax authorities on transfer pricing issues leads to tax disputes, including those that are considered in court. Administrative litigation involves the use of an effective tool in resolving tax disputes on transfer pricing, namely forensic economic examination. The peculiarities of conducting tax audits on transfer pricing and the use of forensic economic examination as an effective mechanism in tax disputes on transfer pricing are studied. The analysis of judicial practice in this area allowed to establish groups of disputes on transfer pricing, which are considered by the Administrative Court of Cassation within the Supreme Court. It is established that the consideration of tax disputes on transfer pricing includes three mandatory elements: economic analysis, facts (circumstances) and the legal component (tax legislation). Forensic economic examination is an effective tool for resolving pre-trial or investigative conflicts of interest between the tax service and the taxpayer of the “economic analysis” component. Approaches to the formulation of questions submitted for the decision of forensic economic examination on transfer pricing are studied. It is determined that the conclusions of forensic experts form a qualitative and thorough evidence base of taxpayers in tax disputes in the field of transfer pricing.

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Section: The Allocation Of Upside and Downside Risks Among Stakeholdersmentioning

confidence: 99%

Судова Економічна Експертиза З Питань Трансфертного Ціноутворення

Фоміна¹,

Shushakova²

2024

ЕУ

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show abstract

“…The focus of tax legislation shifts from direct taxes to indirect ones, at least in the EU27 (Dugová, 2013). Tax is, at least partially, beyond any doubt a price for public services (Hettich, 2005, p. 420).…”

Section: The Allocation Of Upside and Downside Risks Among Stakeholdersmentioning

confidence: 99%

Risks and Transfer Pricing Regulation at the Multinational Enterprises' Routine Units: A Literature Review

Buus¹

2018

Prague Economic Papers

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Multinational enterprises (MNE) allocate valuable intangible assets and strategic functions to the strategy units (usually parent companies) for that allows them to impropriate the majority of the profits there and protect those assets from subsidiaries' risks. The subsidiaries are frequently routine units. Subsequently, the routine units receive low reward, as they perform only routine functions. The OECD transfer pricing guidelines support that practice to the detriment of government budgets and public by considering the routine units as the low-risk ones. This paper reviews the relevant literature and shows that the traditional view of risk and profit allocation between strategy and routine units is inconsistent with their relative risks, resp. with relative risks of MNE's subsidiary and independent company. The long-term perspective of MNEs' members' downside risks provides correct information for transfer pricing regulation and fiscal authorities. Results of this paper enable proposal of the transfer pricing risk analysis targets and tools.

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Changes in the Value Added Tax as the Tool against the Global Crisis

Cited by 2 publications

References 8 publications

Судова Економічна Експертиза З Питань Трансфертного Ціноутворення

Судова Економічна Експертиза З Питань Трансфертного Ціноутворення

Risks and Transfer Pricing Regulation at the Multinational Enterprises' Routine Units: A Literature Review

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