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MINIMIZATION OF TAX RISKS AT THE REPORTING OF INCOME FROM FOREIGN ORGANIZATIONS

Elena Shuvalova, I. Kurochkina, N. Sibatulina, A. Yershov

Abstract

The problems of minimizing tax risks when Russian companies paid income to foreign organizations were constantly in the focus of attention of economists and practitioners. The number of publications of both foreign and Russian researchers in this field has a steady upward trend. This is due to the observed increase in the number of foreign organizations receiving income from sources located on the territory of Russia, as well as the expansion of the range of controversial issues arising in the current conditions for the development of tax relations. The singularity of the legal basis of taxation hampers the development of entrepreneurial activity and the harmonization of tax relations. A large proportion of controversial issues can be resolved if the ideology, theory and methodology of organization and conduct of tax control change, which must meet the modern requirements and principles of the digital economy. Improving the organization and conduct of tax control over the performance of economic entities of their tax obligations should be aimed at finding new innovative methods for its implementation, which should qualitatively change the tax relations. Instruments of tax control should: ensure minimization (warning) of tax risks of the possibility of understating by the economic entity of its tax liabilities, which can significantly hamper the achievement of a balance of interests of all participants in the tax process; ensure voluntary compensation of losses of budget revenues of the state by organizations in case of failure to fulfill their tax obligations. The study of tax risks should ensure a quantitative assessment of the level of risk of non-receipt of a tax obligation for the state, and for a taxpayer - the degree of compensation for tax losses. The purpose of the article is to summarize the theoretical and practical experience of tax control, to find effective methods and tools for minimizing tax risks, in terms of paying income in favor of foreign organizations. The object of the study is the tax risks associated with the payment of income in favor of foreign organizations by the example of transactions with derivative financial instruments: option and swap.

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