Tax control of transfer pricing

The current global financial market is witnessing the activation of cryptocurrency as a payment instrument and a means of accumulation. However, the risks of money laundering, terrorism financing and tax evasion that cryptocurrency transactions imply lead to the need to implement their state regulation, an important component of which is tax control.
Therefore, the purpose of the article is to substantiate the value orientations when forming the system of cryptocurrency transactions tax control in Ukraine taking the positive experience of developed countries into account. The scientific results of the study consist in the emphasizing structural, functional, systemic and institutional approaches to understanding tax control, which became the basis for identifying the features of cryptocurrency transactions as a tax control object.
It was revealed that the lack of personalization of the agreement parties, the relatively high level of information security, free international turnover and a decentralized payment system are the factors of the cryptocurrency market further development. On the other hand, this leads to the loss of tax revenues for Ukrainian budgetary system, taking into account the forecasted trends in the development of the cryptocurrency market by 2022 through methods of sums, least squares and expert estimates. Given the institutional approach to the understanding of tax control, an institutional structure of the cryptocurrency transactions tax control in Ukraine is proposed.
It is established that domestic state institutions are able to carry out tax control over these transactions. It is also determined that introducing fiscal control will result in the receipt of additional revenues by budgets, reduction of shadow economy, counteraction to cybercrime and terrorism financing.
The practical importance of the results is in the need to form an effective system of cryptocurrency transactions tax control as a function of public administration.
It has been determined that transactions on cryptocurrency supply, on the determining exchange rates and transactions on cryptocurrency disposal should be an object of tax control in Ukraine. Mining transactions, receipt of income (profits) in the cryptocurrency are subject to general taxes, depending on the taxpayer’s legal status, in particular, personal income tax, corporate income tax and a unified social tax (UST). Taking into account the EU recommendations on the non-application of value added tax in the cryptocurrency transactions taxation, it is not appropriate to implement it in this area. Establishing tax control over cryptocurrency transactions will expand the powers of state authorities that are empowered to control observing financial discipline by economic agents in Ukraine and the financial capabilities of state and local budgets.

In calculating the transfer price of a transaction for goods, services, intangible assets, or financial transactions, a corporation has a policy known as transfer pricing. Due to its widespread abuse, transfer pricing is frequently associated with negative connotations. For example, this practice manipulates prices so that it has the potential to harm state revenues. This study uses tax expenses as a moderating variable to evaluate how intangible assets, debt covenants, and bonus systems affect the company’s decisions to use transfer pricing. This paper uses quantitative research approach with multiple linear regression analysis. The data used are panel data, consisting of cross-section data from 23 international manufacturing businesses on the Indonesian Stock Exchange, and time-series data from 2017 to 2019. Based on the tests, only the debt covenant variable significantly positively affects the transfer pricing action (sig. 0.000). In contrast, the intangible asset and the bonus mechanism variables are insignificant for transfer pricing. Furthermore, tax charges cannot mitigate the impact of intangible assets on transfer pricing decisions. However, tax charges may be able to mitigate the debt covenant in a way that makes the company’s decision to use transfer pricing stronger (sig. 0.024). Additionally, the bonus mechanism may be negatively moderated by tax expenses, weakening the company’s decisions to use transfer pricing (sig. 0.045).

The tax administration effectiveness depends on the level of tax revenues and economic system functioning and the stable economic development of any government. The article considers institutional aspects of tax administration. The purpose of this study is to describe, evaluate and search for the development prospects of the organizational model of tax administration. The authors describe the contemporary condition of the Republic of Kazakhstan tax authorities’ organizational structure. Moreover, the international practices of the tax administration’s organizational system in modern realities is overviewed. The tax administration effectiveness is evaluated by the correlation-regression analysis of the tax authorities’ activity indicators. As a result, the relationship between the degree of effectiveness of tax administration and key performance indicators of tax authorities were identified and evaluated. Based on the conducted theoretical research, this paper reviewed tax administration’s partner system within the perspective innovative development framework. The research results are of interest to economists and public officials in the tax audit field.