MEASURES AGAINST AGGREGATE TAX PLANNING IN UKRAINE

The article examines the problem of transfer pricing, the nature and stages of the formation of international standards for the prevention of aggressive tax planning, rules to counteract the erosion of taxable profit / tax base and the withdrawal of profit from taxation. The purpose of the article is to investigate the background and stages of the evolution of transfer pricing and the state of implementation of the basic rules of the BEPS (Base Erosion and Profit Shifting) Plan in Ukraine. Withdrawal of profit from taxation becomes possible because of the contradictions between the facts and norms of tax legislation in different countries, so the creation, support, improvement and implementation of international tax standards is an important practical and theoretical problem. The examination of problems with international taxation and ways of their solution, have been reflected in scientific works since the middle of the XIX century. Since the end of the twentieth century, theoretical developments have become the basis for the implementation of large-scale and multilateral tax reforms, a feature of which has been the formation of standards and rules for international taxation as the economy has become global and national budgets continue to remain national. The methodological basis of international model tax conventions is the doctrine of economic connectedness, according to which a country that is a source of income gains legal rights to tax natural or legal persons-residents located in its territory. The authors identified four stages in the formation of modern approaches to the international regulation of transfer pricing, the basis of periodization is the state of coordination of national tax policies. The article analyzes the content and state of implementation of the BEPS rules that Ukraine has assumed, and the authors conclude that, although Ukraine has not yet fully aligned its legislation with OECD recommendations, it is confidently moving towards full implementation of the expanded BEPS package. The implementation of world standards will help eliminate technical and logical discrepancies in national tax legislation and should enhance the effectiveness of the transfer pricing control mechanism.