Implementation of step 13 of the BEPS Action Plan in the context of introducing automatic exchange of information for tax purposes

Abstract

The precondition for Ukraine's accession to the multilateral agreement on automatic exchange of interstate reports is the introduction of the Report by countries of the international group of companies (hereinafter - the intercountry report), which is part of the OECD-recommended three-tier transfer pricing documentation model (Action Plan 13, BEPS Action Plan 13). It has been proven that the implementation of the intercountry report is in the early stages of the implementation of Step 13(tax legislation establishes the obligation of multinational enterprises to submit such reports; the form and procedure for its preparation are designed , but there is no mechanism for ensuring confidentiality and appropriate use of information of such reports). The conclusion is made on the need to further improve the legislation of Ukraine in the field of international exchange of information for tax purposes and the relevance of research on these issues.