Сountry-by-country reporting: appropriate use and confidentiality in automatic information exchange

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.

Automatic international exchange of tax information: features of the preliminary conditions of implementation in Ukraine during the wartime

CHUKHRAIEVA¹,

OLIYNYK²

2022

Automation of preparation and tax administration reporting processes across countries: conceptual approaches

NIKOLENKO¹

2022

Introduction. Preparation of Country-by-Country Reporting (CbCR) in accordance with the requirements of BEPS13, which is submitted by the parent company of an international group of companies to the jurisdiction by location, should be automatic and based on accounting and financial data. Companies need to prepare a consistent three-level reporting package that discloses information about the global distribution of income, economic activity of companies at the global level. In this regard, there is a need for IT tools to support the implementation of the initiative to comply with contractual obligations to exchange information. Problem Statement. The lack of a conceptual solution to automate the process of preparing the CbCR report, which will allow to prepare the report considering the characteristics of groups of companies and ensure the confidentiality of its use and tax administration, makes it impossible to obtain information quickly. Purpose. Highlighting the prospects for the introduction of the standard for automatic exchange of tax information in Ukraine and setting tasks for the development of a universal solution for automating the processes of reporting and tax administration in order to combat income tax evasion. Methods. General scientific and special methods are used: analysis, synthesis, grouping, description, comparison, system approach, modeling and generalization. Results.The basis for the preparation and analysis of the CbCR report for further automatic exchange, in accordance with the BEPS plan (step 13), is the automation of reporting, which is based on the construction of a unified accounting methodology, optimization of CbCR preparation methods, integration with the accounting systems of various members of the МGC and updating XML schemas with considering the requirements of different tax jurisdictions. It is the development of a comprehensive solution that includes analytical, methodological tools and has a reliable degree of protection to preserve the confidentiality of information, which will help to get an overall picture of the current tax situation of the MGC and the profit erosion risks. Conclusions. In order to achieve the set goal and objectives, conceptual approaches are presented for the development of a universal solution for automating the processes of reporting and tax administration with the aim of countering BEPS in the areas of implementation of OECD norms on the confidentiality of information that is the subject of international exchange.

International experience in identification of tax risks according to the data obtained within the framework of international exchange of information

Kryshtopa¹,

OLIYNYK²,

BABIY³

2022