Registration Number
0223U003299,
0122U200253
, R & D reports
Title
Improving the mutual agreement procedure taking into account the provisions of international agreements of Ukraine on the avoidance of double taxation
popup.stage_title
Head
Tymchenko Leonid D., д.ю.н.
Registration Date
12-04-2023
Organization
State Tax University
popup.description2
Report: 105 pages; 1 figure; 3 tables; 57 sources; 3 additions.
The object of the research is the legal relations that arise during the implementation of the mutual agreement procedures (МАР) in accordance with the provisions of international treaties of Ukraine on the avoidance of double taxation.
The purpose of the study is to improve the procedure of mutual agreement based on the treaties of Ukraine on the avoidance of double taxation, taking into account the positive world experience, and to develop proposals for the effective use of the relevant mechanism in Ukraine.
The methodological basis of the research is a system of general scientific and special methods and approaches, which should provide an objective analysis of the studied phenomenon. Taking into account the topic, purpose and tasks of the research, the following methods were used: dialectical (characterization of the advantages and problematic aspects of the use of the МАР as a mechanism for resolving tax disputes); historical and legal (characteristics of the evolution of the normative regulation of the МАР); comparative legal (identification of the common and distinctive features of the domestic approach to the regulation of the implementation of the МАР in the context of world practice); formal and legal (development of proposals for improvement of regulatory frameworks and law enforcement practice in the context of using the potential of the МАР in Ukraine); structural-functional method (determining the role of the MAP and its relationship with other tools).
A draft of amendments to Article 108-1 of the Tax Code of Ukraine "Course for carrying out the procedure of mutual agreement" is proposed, aimed at improving the course for carrying out the МАР, taking into account the provisions of the treaties of Ukraine on the avoidance of double taxation. The results of the research work will ensure the settlement of certain problematic issues of improving the mutual agreement procedure.
Product Description
popup.authors
Kononenko Valery Petrovich
Selezen Pavlo Oleksandrovych
Tymchenko Leonid D.
Trubina Marina V
Fedchuk Svetlana Igorevna
Shkurenko Nataliia
popup.nrat_date
2023-04-12
