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.

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.

In the current conditions of globalization and European integration trends, domestic agricultural companies use the transfer pricing mechanism when exporting agricultural products, which on one hand allows owners to increase the efficiency of internal management, and on the other to hide real profits and reflect unprofitable production in financial statements. At the same time, traditional double-entry bookkeeping and financial reporting (including those prepared in accordance with IFRS) are unable to show the real power momentum of domestic agricultural enterprises profitability (their return on capital). This narrows the circle of potential investors when making decisions on the feasibility of investing financial resources in the development of Ukrainian agricultural sector. The purpose of the study is to develop a 3D-form of the Actuarial Report on Capital Force Impulse (3D - ARCFI), which informational content will provide an objective assessment of the capital force impulse of an agricultural enterprise and help to attract investment in its development. The object of the study is the process of actuarial accounting and 3D reporting as information subsystems for controlling the capital power momentum at domestic agricultural enterprises. The research methodology is based on the application of 3D-recording method and classical mechanics methods in displaying information from the actuarial accounting system on 3D-force accounts to develop a model of power momentum management of an agricultural entity return on capital as an alternative approach to transfer pricing based on informational filling of 3D-ARCFI with the help of net profit method. The study results showed dependence of domestic agricultural enterprises investment attractiveness on the qualitative informational filling of the actuarial management reporting in 3D format. The practical value of the results received confirmed the effectiveness of the proposed 3D-model of profit power momentum management within the transfer approach based on accounting-informational basis of 3D-ARCFI, which will contribute to an objective perspective assessment of agricultural companies return on equity power momentum and increase their market investment attractiveness.

Acknowledgment
The article has been prepared within the research project “Business Value Management” (state registration No. 0118U000131) implemented in the Kyiv National University of Trade and Economics.