Registration Number
0223U003306,
0122U200261
, R & D reports
Title
Advance pricing agreement in controlled operations: international experience and Ukraine
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Head
Karmalita Mariia V., Доктор юридичних наук
Registration Date
13-04-2023
Organization
State Tax University
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Report: 180 pages; 12 figures; 6 tables; 111 sources.
The object of the study is social relations arising in the sphere of ensuring control over transfer pricing.
The purpose of the study is to improve the procedure of advance pricing agreement (APA) taking into account the positive world experience and to develop proposals for its effective use in Ukraine.
The methodological basis of the research was the use of a set of general scientific and special methods of scientific knowledge, namely: dialectical; historical and legal; comparative legal; formal and legal; structural and functional methods.
As part of the work, a comparative legal characterization of the key stages of APA implementation in Ukraine and member states and non-member states of the EU and OECD was carried out; modern trends in the development of APA in the context of the experience of foreign countries are highlighted and analyzed; the mechanism of bilateral or multilateral APA conclusion in foreign countries is defined; the extent of the rights and obligations of the taxpayer and the supervisory authority regarding the control over the execution of APA contracts was investigated, possibility of refusal or extension of the APA contract, analysis of the conditions under which the contract may be terminated or annulled, possible consequences for the taxpayer and the supervisory authority in case of early termination or cancellation of the APA contracts; the ways of solving inconsistencies between the legislation of Ukraine and the counterparty's state in terms of the provisions of conclusion, extension and termination (cancellation) of APA contracts are determined; the expediency of changing the existing approach to APA implementation, taking into account modern trends in the development of relevant procedures in other jurisdictions; the need for state regulation, analysis of the impact on the market environment, ensuring the rights and interests of taxpayers.
Product Description
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Boreiko Nataliia V
Varnalii Zakharii S.
ZADOROZHNIA LINA
Karmalita Mariia V.
Kovtunovych Nataliia L
Koshchuk Tetiana V.
Novytska Nadiia V.
Selezen Pavlo Oleksandrovych
Starodub Dmytro M.
Fradynskyi Oleksandr A.
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2023-04-13
