The institutional model of tax administration and aspects of its development

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.

Nowadays, the modernization of the education system is the basis of dynamic sustainable economic development and citizens’ well-being. The key agent for the implementation of educational policy and the developer of the legal framework governing the functioning of the educational sphere is the state and its bodies. The Kazakhstani state policy’s main priorities in the field of education are formulated in several strategic documents. Using the review approach, this article examines the current state of public policy and legal regulation in Kazakhstan’s education sector. The article analyzes key documents that define the contours and content of the main directions of public policy and legal regulation. This article attempts to identify, review, and analyze the legal characteristics of the key process and factors existing in the legal field of Kazakhstani education, such as “Bologna factor,” “soviet legacy,” “provision of quality,” etc. The article concludes that the existing legal tools do not fully comply with law enforcement practice. The interpretations of some legal acts are somewhat different, which causes difficulties for actors providing educational services. Based on the result of the analysis, the article provides the main recommendations for improving legislation in education.

Acknowledgment
This article was written under grant from Kazakhstan Ministry of Education and Science No. АР05135081 “Student with disabilities and distance education learning environment: socio-practical and legal dimensions” coordinated by Prof. Dr Zulfiya Movkebayeva (Abai Kazakh National Pedagogical University).

The subject of the scientific work is analysis of the essence of the “transfer pricing” concept. It has been proven that transfer pricing is an economic and legal tool used by business entities for their tax burden optimization.

It has been concluded that the concept “transfer price” means the price generated by multinational corporations in the process of commercial activity between the affiliated companies located in different countries and, correspondingly, different tax jurisdictions. In essence, transfer pricing means intra-company pricing of goods transferred between the enterprise subdivisions located in different countries. Base erosion by means of transfer pricing can be performed not only based on the price manipulating by the affiliated companies, but also as a result of manipulating incomes and expenditures. The latter is accompanied by the financial resource withdrawal outside the national economy and its concentration in the low taxation jurisdictions.

Transfer pricing bears serious risks both for an individual country and for the world economy. Contractual freedom of transnational corporations and industrial and financial groups cannot be unlimited regardless of the principle of freedom of contracts in the private law relations. Economic activity of such business entities must subject to a strict control on the part of the country. In the process of transfer pricing tax control, the controlling state agencies are intended to prevent the decrease of tax liabilities by shifting the income to low tax jurisdictions by taxpayers.