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1
Andjelkovic, Mileva. „Tax avoidance: Definition and prevention issues“. Zbornik radova Pravnog fakulteta, Nis, Nr. 67 (2014): 79–98. http://dx.doi.org/10.5937/zrpfni1467079a.
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Satyadini, Agung Endika. „Empirical Approach of Tax Avoidance Risk Assessment“. Kajian Ekonomi dan Keuangan 2, Nr. 1 (05.09.2018): 52–69. http://dx.doi.org/10.31685/kek.v2i1.344.
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This study analyzes tax avoidance risk assessment including dimension and magnitude of tax avoidance risk exposure using several enterprise-related and government-related variables. Providing far-reaching analysis and examining a relatively unexplored area of conforming tax avoidance, this study employs two measurements of tax avoidance including non-conforming and conforming tax avoidance. As an extensive analysis, this paper also examines the magnitude of tax avoidance responsiveness with respect to different types of enterprises including Permanent Establishment and foreign-invested enterprises. The results drawn from this study are paramount as the empirical approach to in tax policy formulation. Risk profiles suggested in this research are pertinent to risk engine of Compliance Risk Management (CRM) and also beneficial for Risk-Based Audit strategy formulation. Ensuring the best-fit policy formulation, these results revealed that application of tax authority’s strategy to hike tax compliance should be more likely to prevention rather than reaction. Furthermore, in the brain area of academic research, the findings also contribute to the field of tax literature by providing simultaneous empirical models including conforming and non-conforming tax avoidance model, which has been relatively unexplored in prior studies.
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Szołno-Koguc, Jolanta, und Natalia Ołówko. „The phenomenon of tax avoidance – the essence, causes and measures (clauses) of prevention in the EU“. Annales Universitatis Mariae Curie-Skłodowska, sectio H – Oeconomia 53, Nr. 3 (28.11.2019): 73. http://dx.doi.org/10.17951/h.2019.53.3.73-83.
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<p>The problem of tax avoidance in the European Union (EU) has existed since the beginning of the EU internal market and is an important aspect at both the national and international levels. Among the most important reasons for this phenomenon are the inconsistent regulations and solutions applied in the tax systems of individual countries, the diverse and complicated nature of fiancial instruments and structures, the insufficient cooperation of tax administrations in EU countries or harmful tax competition. This state of affairs causes negative consequences for the budgets of individual countries and discriminates against honest taxpayers, because tax profits derived from tax evasion are invested in a competitive struggle against companies that reliably settle accounts with the tax authorities. The construction of an efficient and effective, yet fully fair tax system in the EU is intended to eliminate or significantly reduce the problem of tax avoidance. This is achieved by the measures currently underway (e.g. the introduction of a directive against tax avoidance or the elaboration by the Organisation for Economic Co-operation and Development (OECD) regarding the recommendations for local administrations in the field of national tax regulations). This article aims to highlight the importance of the tax avoidance problem and to present selected actions to solve it at both the national and EU levels. The structure of the study has been subordinated to the above, as along with the applied research method, including the analytical and conceptual approach.</p>
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Beebeejaun, Ambareen. „The Anti-Avoidance Provisions of the Mauritius Income Tax Act 1995“. International Journal of Law and Management 60, Nr. 5 (10.09.2018): 1223–32. http://dx.doi.org/10.1108/ijlma-07-2017-0174.
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Purpose A taxpayer who gets caught under Part VII of the Mauritius Income Tax Act is subjected to a corrective measure only in the form of payment of the amount of tax that would have been due in the absence of the avoidance arrangement, but the consequences set out in the same section do not result in any disincentive to the taxpayer that would ensure the prevention of the occurrence of such type of anti-avoidance practices in the future. This study aims to investigate the effectiveness of the anti-avoidance provisions in the Mauritius legislation as a weapon against impermissible tax avoidance, and the study also intends to critically analyse the remedies available against taxpayers who enter into impermissible tax avoidance transactions. Design/methodology/approach The methodology adopted for this qualitative study consists of a critical analysis and comparative legal review of the relevant legislation, case laws and literature. The anti-avoidance provisions of the Mauritius legislation will be compared with similar provisions of legislations of countries that have rigid preventive rules for anti-avoidance practices, and the selected countries are the UK and Australia because each country has been successful in diminishing the tax avoidances practices further to the imposition of penalties for impermissible tax avoidance. The black letter approach will also be used through which existing legal provisions, judicial doctrines, scholar articles and budget speeches governing anti-avoidance provisions for each country identified will be analysed. Findings Further to an analysis of the substantial differences between Mauritius anti-avoidance legal provisions and those of the UK and Australia, it is found that the backing of corrective actions by penalties act as a disincentive to prohibit impermissible anti-avoidance practices. The study concludes that, where there is abuse of law, the law needs to provide for penalties that must be suffered by the abuser, and hence, the study calls for an amendment in the Mauritius Income Tax Act to strengthen anti-avoidance provisions, by adopting similar provisions of the laws of Australia and the UK. Originality/value At present, there is no Mauritius literature on the researched topic, and this study will be one of the first academic writings on the subject of penalties for impermissible tax avoidance in Mauritius. The study is a new and unique topic in Mauritius, and for that reason, the study will largely rely on foreign sources that deal with penalties for impermissible tax avoidance, and this will include the Australian Taxation Administrative Act 1953, Australian case laws and the UK Finance Act 2016. This study is being carried out with the view to provide insightful recommendations to the stakeholders concerned in Mauritius to enhance the revenue collection avenues and methodologies for the Mauritius revenue authorities.
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Czerwińska-Sabała, Katarzyna. „Intertemporal issues related to anti-tax avoidance clause on the example of the resolutions of the Council for Anti-Tax Avoidance of 18 December 2019“. Doradztwo Podatkowe - Biuletyn Instytutu Studiów Podatkowych 3, Nr. 283 (31.03.2020): 18–21. http://dx.doi.org/10.5604/01.3001.0014.0633.
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The article discusses the line of the Council for the Prevention of Tax Avoidance in terms of intertemporal issues of the anti-tax avoidance clause and decisions of the creation moment of the tax benefit. The considerations refer to the Council resolutions No. 3/2019-5/2019 of 18 December 2019 and constitute the part of the first opinions of this institution regarding the application of the art. 119a of the Tax Ordinance Act.
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Lohvyn, Andrii. „PREVENTION OF OFFENCES IN THE SPHERE OF VALUE ADDED TAX ADMINISTRATION“. Administrative law and process, Nr. 3 (30) (2020): 69–85. http://dx.doi.org/10.17721/2227-796x.2020.3.06.
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In the article the author explored the legal regulation of counteraction to VAT evasion (avoidance by taxpayers of their tax liability by minimizing tax liabilities), which is a specific type of activity of tax authorities. The continuous development of public relations in the field of taxation in Ukraine requires effective application of administrative prevention (counteraction) measures in this area and, of course, the qualitative state of legal regulation of these measures. In the legal literature, administrative prevention measures were mainly studied in terms of conceptual and categorical apparatus and their classification. To date, considering the introduction of electronic administration of value added tax, studies on the use of administrative prevention measures by public authorities in the scientific field have not been analyzed. Taking into account international experience and based on a systematic analysis of the current legislation, the author deals with the legal mechanism for counteracting evasion from paying value added tax by means of introducing electronic administration of value added tax. The author notes that with the introduction of automated monitoring of risk assessment (taking into consideration the criterion of the amount of paid value added tax) (the so-called “tax burden” and/or “tax return”), the state is trying to increase budget revenues. The author concludes that administrative prevention (counteraction) measures used by regulatory authorities, in a sense, are the tools by which it is possible to achieve timely response to the activities of taxpayers aimed at tax evasion. It was substantiated that automated monitoring of compliance of tax invoices with the risk assessment criteria can be considered as a preventive measure, according to which taxpayers’ transactions aimed at forming an illegal tax credit are detected by regulatory authorities. In turn, making decisions if a payer of value added tax meets the Criteria of being a risky payer, and accordingly, further suspension (blocking) of registration of tax invoices of the specified payer, is a measure to counteract evasion from paying value added tax. It was proved that from the legal point of view, the legal mechanism of administrative prevention (counteraction) measures, in particular, those regarding the implementation (conducting) of automated monitoring, should contribute to the avoidance of legal collisions and contradictions that arise between regulatory authorities and taxpayers.
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Yakovlev, Pavel Igorevich. „International development of the concept of taxation of a permanent representation of a foreign company as an “independent taxpayer” and the experience of its application in the Russian Federation“. Налоги и налогообложение, Nr. 3 (März 2021): 16–25. http://dx.doi.org/10.7256/2454-065x.2021.3.35795.
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The subject of this research is the development of the concept of taxation of permanent representations of foreign companies on the international level and its application in the Russian Federation. The object of this research is the permanent representations of foreign companies. The author examines such aspects of the topic, as the use of agreements on avoidance of double taxation, countering the tax base erosion, and the international approach towards taxation of the permanent representation of a foreign company as an independent participant of the market relations. Analysis is conducted on the need for amending the Model Agreement of the Russian Federation of 02.24.2010 No. 84 “On conclusion of intergovernmental agreements on avoidance of double taxation and on prevention of tax evasion on the income and property”. The author traces the transformation of attitude of international tax organizations towards the concept of permanent representation and substantiation of their choice of the concept of taxation of a permanent representation as an independent taxpayer. The scientific novelty is proven by the facts of application of this concept of taxation of permanent representation in the national legislation of multiple countries, international agreements on avoidance of double taxation, Russian national tax legislation and arbitration practice. The main conclusion consists in the response to the selected by the international tax organizations concept of taxation of a permanent representation. The author offers to amend the Model Agreement of the Russian Federation of 02.24.2010 No. 84 “On conclusion of intergovernmental agreements on avoidance of double taxation and on prevention of tax evasion on the income and property”.
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Bae Khee Su. „A Study on the Improvement of Tax Avoidance Theory and Prevention System“. Tax Accounting Research ll, Nr. 40 (Juni 2014): 129–46. http://dx.doi.org/10.35349/tar.2014..40.007.
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Bimo, Irenius Dwinanto, Christianus Yudi Prasetyo und Caecilia Atmini Susilandari. „The effect of internal control on tax avoidance: the case of Indonesia“. Journal of Economics and Development 21, Nr. 2 (07.10.2019): 131–43. http://dx.doi.org/10.1108/jed-10-2019-0042.
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Purpose The purpose of this paper is to analyze the effect of internal control on tax avoidance analyzing internal (family ownership) and external (environmental uncertainty) factors on the effectiveness of internal control in preventing tax avoidance. Design/methodology/approach First, the authors examine the direct effect of the effectiveness of internal control on tax avoidance. Second, the authors examine the effect of moderation of family ownership and environmental uncertainty on the relationship of the effectiveness of internal control on tax avoidance. Third, the authors divide the full sample into two groups, high and less effectiveness of internal control to examine the direct effect of internal control effectiveness on tax avoidance and when considering moderating variables. Fourth, the authors use two different measures of the effectiveness of internal control. Findings This research found that effective internal control can reduce tax avoidance. Family ownership affects the relationship between internal control and tax avoidance, but environmental uncertainty does not influence the relationship between internal control and tax avoidance. Practical implications Internal control increases compliance with rules and policies, so companies must design and implement effective internal control to prevent tax avoidance activities in violation of tax regulations. Originality/value In contrast to previous studies, this study measures the effectiveness of internal control using the index of internal control practice disclosure and considers internal and external factors that can affect the effectiveness of internal control to prevent tax avoidance.
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Kovač, Polonca. „The potentials and limitations of tax dispute prevention and alternative resolution mechanisms“. Zbornik Pravnog fakulteta Sveučilišta u Rijeci 39, Nr. 4 (2019): 1505–28. http://dx.doi.org/10.30925/zpfsr.39.4.3.
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This paper deals with prevention and alternative dispute resolution (ADR) in tax matters, particularly in the light of the specific nature of administrative relations, which also include tax procedures. Given the involvement of stakeholders, ADR benefits both the taxpayers and the tax authority, enabling greater legal certainty and speedier finalisation of procedures. Yet, ADR also poses an open threat to the public interest and equality as international and constitutional administrative principles, and must therefore be limited in tax procedures. This also derives from the legal acts of the EU and the Council of Europe. In addition to theoretical frameworks and types of dispute prevention and resolution mechanisms studied by means of scientific literature review, legal sources analysis and comparative insights, the paper presents the Slovenian regulation and practice of the Financial Administration (FURS) over the past years. The aim of this research is to examine the de iure and de facto situation at the national level. The analysis shows that, in tax matters, ADR is noticeably more intensive at the international level than within national tax systems. On the other hand, individual countries prefer to establish regulatory mechanisms for prevention, which should result in even more desired avoidance of disputes. It can be concluded that efficient tax procedures require an integrated approach, including both dispute prevention and ADR, in order to ensure the principles of tax justice and systemic inclusion of all stakeholders in its governance.
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Świerczek, Adam. „Introducing Important Changes Concerning the Avoidance of Double Taxation Between Czech Republic and Poland“. International and Comparative Law Review 14, Nr. 2 (01.12.2014): 83–92. http://dx.doi.org/10.1515/iclr-2016-0053.
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Abstract On January 1, 2013 a new treaty between the Czech Republic and the Republic of Poland dealing with avoidance of double taxation as well as prevention of tax evasion in the field of income tax has come into effect. The treaty newly introduced the taxation of income of the permanent establishment, changes in rates of dividend taxes, interest rates and royalties, and, last but not least, what has been altered is even the definition of royalties. Furthermore, the treaty also brings a new adaptation of the profits of associated enterprises. Approval of the clause regarding exchange of information as well as cancellation of the tax-sparing clause is a novelty. This article is dealing with the description of the changes and novelties and the indication of the potential importance.
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Sullivan, Brandon A., Joshua D. Freilich und Steven M. Chermak. „An Examination of the American Far Right’s Anti-Tax Financial Crimes“. Criminal Justice Review 44, Nr. 4 (21.04.2019): 492–514. http://dx.doi.org/10.1177/0734016819839772.
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Little attention has been paid to ideologically motivated tax protesters who use frivolous legal arguments as moral or legal justification for committing tax fraud and related financial crimes. These crimes have defrauded private citizens and governments and are associated with violent far-right extremism, negatively impacting public safety and stability. Using data from the U.S. Extremist Financial Crime Database, we provide an exploratory, descriptive analysis of the composition and motivation of financial crime schemes associated with the American far-right extremist anti-tax movement. Our innovative open-source database permits systematic empirical research into connections among tax avoidance, anti-tax, and anti-government belief and related criminal behavior, which is necessary for the advancement of scholarship on the causes and consequences of these frauds and the development of sound intervention and prevention policies and practices.
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Egholm Elgaard, Karina Kim. „A comparative analysis of VAT grouping schemes from a Nordic perspective—aspects of tax avoidance and fiscal competition“. Nordic Tax Journal 2017, Nr. 1 (26.05.2017): 1–25. http://dx.doi.org/10.1515/ntaxj-2017-0001.
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Abstract Value-added tax (VAT) grouping schemes, whereby several legally independent entities are treated as a single taxable person for VAT purposes, are well known, though their detailed rules differ from country to country. This article deals with specific tax avoidance and fiscal competition aspects of VAT grouping schemes in Denmark, Norway, and Sweden. The article gives examples of tax abuse and avoidance by using various VAT grouping models, with the main emphasis on the practice in Denmark, which may be indicative of similar problems in other countries. The article shows that there are significant differences in the rationales for national VAT grouping schemes, and these indicate that there are mismatches between the national schemes of the EU Member States and the original intention of the EU scheme. Finally, an examination of the different national rationales shows the necessity of striking a balance between combating tax avoidance and preventing distortion of competition.
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Lim, Sang-Bin und 차승민. „A Study on Local Tax Reduction System for Preventing a Holding Company from Tax Avoidance“. Tax Accounting Research ll, Nr. 50 (Dezember 2016): 59–81. http://dx.doi.org/10.35349/tar.2016..50.004.
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Tymchenko, Leonid, und Pavlo Selezen. „The Concept of Beneficial Owner in Application of the Ukrainian Double Taxation Treaties“. Juridica International 24 (09.10.2016): 55. http://dx.doi.org/10.12697/ji.2016.24.06.
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The term ‘beneficial owner’ has been applied by Ukrainian courts and tax authorities in the area of application of the provisions of double-taxation treaties since the adoption of the Tax Code of Ukraine, in 2010. The changing nature of the concept of beneficial owner, its importance as an instrument for counteraction of treaty shopping, and the necessity of improvement of its application in the Ukrainian reality are the main factors that have a strong impact on the development of national practice in the application of the concept of beneficial owner. The article focuses on the main challenges to application of the concept of beneficial owner in the context of prevention of tax avoidance as one of the purposes of double-taxation treaties in Ukraine.
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Хаванова, Инна, und Inna Khavanova. „Concept of Beneficiary Owner (Proprietor) in Tax Law“. Journal of Russian Law 2, Nr. 12 (01.12.2014): 0. http://dx.doi.org/10.12737/6585.
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The concept of beneficial ownership draws the increasing attention because it´s widely used by the international holding structures for tax planning. The author analyzes the concept of beneficial ownership in the tax law taking into account new Russian legislative initiatives and law-enforcement practice. The article touches upon the history of this concept, its content in the international tax law, peculiarities of the ratio of national and international tax law norms, questions of concept application and usage of the term «the person having the actual right to receive the income» in conventions for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. The author concludes that inclusion of the term «the actual addressee (beneficial owner) income» in the Tax code of the Russian Federation for the purposes of the application of the Double tax agreements by itself will not provide for the effective application of the concept which is a result of expert development, carried out within the Organization for Economic Co-operation and Development (OECD) and also case-law of the leading states. The author concludes that there´s a necessity for the scientific researches taking into account the specificity of the Russian legal system, defining the directions of tax and legal researches.
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Zhao, Lijun, Angelina Karaivanova und Pengfei Zhang. „The Complementary Role of the WTO in the Enhancement of the Base Erosion and Profit Shifting Project“. World 2, Nr. 2 (14.05.2021): 267–94. http://dx.doi.org/10.3390/world2020017.
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The current rules on international tax do not function properly due to the gaps which allow for tax manipulation. Whereas most tax agreements largely contribute to the prevention of double taxation, they do not effectively approach double non-taxation matters arising from tax competition based on the agreements’ bilateral nature. In order to tackle this issue, the Base Erosion and Profit Shifting project was introduced. Developed under the Organization for Economic Co-Operation and Development framework, the Base Erosion and Profit Shifting project deals with tax avoidance practices that use mismatches and gaps in tax rules. Nevertheless, the success of this new soft law initiative requires a forum that can promote and enforce its recommendations. The structural nature of the Organisation for Economic Co-operation and Development has led to the consideration of the World Trade Organization to be this forum by many. However, the World Trade Organization covered agreements are drafted in a way that includes some of the tax competition matters but not others, including traditional tax havens. This paper aims to bridge the gaps in the area of the international tax regime. By examining the international trade and international tax regimes, it is shown that there is space for variations in the World Trade Organization broadly drafted agreements for such matters to find a resolution. It is argued that the World Trade Organization can play a complementary role in the enforcement of the new international tax rules.
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Korol, Volodymyr. „EU Members States legislation harmonization relating to controlled foreign companies in the area of anti-tax avoidance“. Legal Ukraine, Nr. 7 (21.09.2020): 36–47. http://dx.doi.org/10.37749/2308-9636-2020-7(211)-5.
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The article is dedicated to the general aspects and peculiarities of the EU Member States legislation harmonization aimed at preventing avoidance of taxation by multinational companies through foreign entities or permanent establishments controlled by parent companies themselves or together with their associated enterprises. On the reasonable basis, the special emphasis was placed on the act of secondary legislation playing the key role in this important area, namely, Council Directive (EU) 2016/1164 of 12 July 2016 laying down rules against tax avoidance practices that directly affect the functioning of the internal market with regard to the controlled foreign companies rules. This Directive came into force on 1January 2019 and became an integral part of EU Anti-Tax Avoidance Package. Harmonization at the regional European level is being provided and, consequently, in-depth researched in the context of OECD/G-20 global Action Plan on Base Erosion and Profit Shifting. From methodological point of view, OECD Final Report on Action 3 BEPS was accepted as the analytical prism allowed the quintessence of constitutive rules of above mentioned EU Anti-Tax Avoidance Directive to be discovered properly. Accordingly, the comparative analysis was conducted through the lens of provisions of vast majority of aforesaid Final Report’s building blocks, more specifically, Rules for defining a CFC, Definition of CFC Income, Rules for computing income as well as CFC exemptions and threshold requirements, in particular, relating tax rate exemption, anti-avoidance requirement, de minimis threshold. Focusing attention on different important aspect related to CFC Income, it’s discovered special considerations of non-distributed income inclusion in the Member State taxpayer’s tax base of certain categories of passive income (interest, royalties, dividends, income from financial leasing, banking, invoicing companies, etc.) or arising from non-genuine arrangements with correlation, respectively, to entity and transaction approaches. Without limiting the foregoing, it’s discovered some argumentative issues considering European researchers as weaknesses of ATAD. It’s offered an illustration cause and effect relationship between non-recognition of passive income to be attributed to controlling parties and CFC’s substantive economic activity as far as there is reason to believe that it refuses to honor case law of the Court of Justice. Key words: controlled foreign company, passive income, substantive economic activity, non-genuine arrangement.
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Coita, Ioana –. Florina, Laura –. Camelia Filip und Eliza-Angelika Kicska. „TAX EVASION AND FINANCIAL FRAUD IN THE CURRENT DIGITAL CONTEXT“. Annals of the University of Oradea. Economic Sciences 30, Nr. 30 (1) (Juli 2021): 187–94. http://dx.doi.org/10.47535/1991auoes30(1)020.
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Preventing and combating phenomenon of tax evasion is a present concern of national governments due to the magnitude this phenomenon represents and because of the increasingly sophisticated techniques used by the authors in carrying out tax frauds. Evolution of tax evasion phenomenon at international level has acquired a profound technological character due to the increasingly elaborate methods. Illegal behaviour has some specific features that could be recognized easily by artificial intelligence models. They use real data in order to derive characteristics that could be identified in due time so that tax avoidant behaviour be identified and prevented. The use of forecasting models like logistic regression, random forests or decision trees in order to model tax avoidant behaviour shows having a good predictive power. Also, the use of the neural networks allowed scientists to calculate probability of an individual taxpayer that would attempt to evade taxes or commit other types of financial frauds. Scientific literature shows an increasing interest in using neural networks to detect and predict fraudulent behaviour in the fields of tax avoidance and financial domain. Cybercrime, cryptocurrency and blockchain were created in order to facilitate payments and help owner in accumulating wealth. Current landscape of financial frauds shows a different picture. Intracommunity frauds are more and more diversified. European Union and International bodies act together to prevent and combat fraud. Could these new technologies possess a real threat to the financial security of our transactions or encourage fraudulent behaviour? This paper tries to find the answer to this question.
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Stratilatova, A., R. Ahmadeev, E. Golubcova und A. Agapova. „Double Tax Treaties: Fiscal Security of the State“. Scientific Research and Development. Economics 9, Nr. 2 (22.04.2021): 65–70. http://dx.doi.org/10.12737/2587-9111-2021-9-2-65-70.
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In today's economy, the basis for optimal tax policy is a holistic approach in the application of international agreements to avoid double taxation. Contracts applicable between jurisdictions are the main instruments for resolving tax disputes and conflicts by taxpayers. The validated double taxation process in each country depends to a large extent on the structure of the tax base, the status of the taxpayer and the established rules for determining taxable income. The object of the study is social relations arising in the field of legal regulation of double taxation. In turn, the subject of study is legal norms, international treaties and agreements regulating social relations arising in the sphere of legal regulation of double taxation. In the practice of international taxation, more than 3000 bilateral international treaties on avoidance of double taxation of personal income and prevention of tax evasion are applied, whereas in Russia, this figure exceeds 80 existing agreements. Under the current legal system, the provisions of double taxation agreements have priority over the provisions of the domestic tax legislation. The analysis of changes in bilateral international double taxation treaties between Russia and Cyprus, Luxembourg and Malta in 2020 allowed identifying important aspects of their legal application and formulating the main tasks necessary for the development of tax potential and successful cooperation in the field of regulation of trade and economic relations.
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KASPEROVYCH, Yuliia. „FUNCTIONAL CAPACITY OF THE TAX SYSTEM OF UKRAINE“. Economy of Ukraine 2020, Nr. 12 (11.12.2020): 36–55. http://dx.doi.org/10.15407/economyukr.2020.12.036.
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The vast majority of scholars have reached a common vision on the fiscal function performance by taxes, in the predominant – on the regulatory (with a division into incentive and deterrent) and to a large extent – on the controlling function. With the change of political cadence and the beginning of COVID-19 quarantine in Ukraine, a number of important tax reforms were launched to de-shadow the economy and establish fairer taxation, which affected all three tax functions. At the same time, systemic problems regarding the functional capacity of the tax system of Ukraine remain on the agenda. First, the failure of the fiscal function of taxes, which is associated with common schemes of tax avoidance and evasion, namely smuggling and “gray” imports, abuse of the simplified taxation system, wages “in envelopes”, unaccounted cash income without the use of cash registers, the erosion of the tax base in low-tax jurisdictions. Second, the limited potential of the regulatory function of taxes due to the weak effectiveness of existing tax incentives. New tax incentives carry the risks of significant revenue losses in the absence of reliable compensators in the future. Third, low confidence in the control function of taxes due to the weak institutional capacity of tax and customs authorities. Complex tax and customs administration provides ample opportunities for corruption risks. There is no effective system of anticipation and prevention of violations. Given the significant number of problems in the implementation of all major tax functions in Ukraine, relevant strategic goals and objectives are proposed to strengthen the functional capacity of the domestic tax system, which should be the basis for strategizing its development.
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Changnam AHN. „A study on Improvements for Residency Rules in the Income Tax Act- for the purpose of preventing offshore tax avoidance -“. Journal of IFA, Korea 31, Nr. 2 (Juni 2015): 253–84. http://dx.doi.org/10.17324/ifakjl.31.2.201506.007.
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Hatta, Hatta. „KONTRADIKTIF PENERAPAN HUKUM PAJAK BERGANDA DI INDONESIA“. Al-Ishlah : Jurnal Ilmiah Hukum 21, Nr. 1 (01.05.2018): 50–58. http://dx.doi.org/10.33096/aijih.v20i1.16.
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This study focused on the policy aspects of the law, especially in the field of tax law. In addition, this study examines and assesses the policy process tax law in determining the double taxation prevention methods which tend to emphasize the comparison method Bilateral and Multilateral Unilateral methods. This research was conducted using the method of normative basing on primary legal materials. The results showed that, emphasizes the aspects of bilateral methods of avoiding double taxation can only regulate the avoidance of double taxation for foreign taxpayers alone, but to set the avoidance of double taxation in the country more appropriate use of unilateral methods. For the method of multilateral results are less than the maximum because there are different interests of countries that enter into agreements.
AbstrakPenelitian ini difokuskan pada aspek kebijakan hukum, terutama di bidang hukum perpajakan. Selain itu, penelitian ini mengkaji dan menilai proses kebijakan undang-undang perpajakan dalam menentukan metode pencegahan perpajakan berganda yang cenderung menekankan metode perbandingan metode Bilateral dan Multilateral Unilateral. Penelitian ini dilakukan dengan menggunakan metode normatif mendasarkan pada bahan hukum primer. Hasil penelitian menunjukkan bahwa, menekankan aspek metode bilateral menghindari pajak berganda hanya dapat mengatur penghindaran pajak berganda untuk wajib pajak asing saja, tetapi untuk mengatur penghindaran pajak berganda di negara tersebut lebih tepat menggunakan metode unilateral. Untuk metode hasil multilateral kurang maksimal karena ada berbagai kepentingan negara yang masuk ke dalam perjanjian.
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Hatta, Hatta. „KONTRADIKTIF PENERAPAN HUKUM PAJAK BERGANDA DI INDONESIA“. Al-Ishlah : Jurnal Ilmiah Hukum 21, Nr. 1 (01.05.2018): 50–58. http://dx.doi.org/10.33096/aijih.v21i1.16.
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This study focused on the policy aspects of the law, especially in the field of tax law. In addition, this study examines and assesses the policy process tax law in determining the double taxation prevention methods which tend to emphasize the comparison method Bilateral and Multilateral Unilateral methods. This research was conducted using the method of normative basing on primary legal materials. The results showed that, emphasizes the aspects of bilateral methods of avoiding double taxation can only regulate the avoidance of double taxation for foreign taxpayers alone, but to set the avoidance of double taxation in the country more appropriate use of unilateral methods. For the method of multilateral results are less than the maximum because there are different interests of countries that enter into agreements.
AbstrakPenelitian ini difokuskan pada aspek kebijakan hukum, terutama di bidang hukum perpajakan. Selain itu, penelitian ini mengkaji dan menilai proses kebijakan undang-undang perpajakan dalam menentukan metode pencegahan perpajakan berganda yang cenderung menekankan metode perbandingan metode Bilateral dan Multilateral Unilateral. Penelitian ini dilakukan dengan menggunakan metode normatif mendasarkan pada bahan hukum primer. Hasil penelitian menunjukkan bahwa, menekankan aspek metode bilateral menghindari pajak berganda hanya dapat mengatur penghindaran pajak berganda untuk wajib pajak asing saja, tetapi untuk mengatur penghindaran pajak berganda di negara tersebut lebih tepat menggunakan metode unilateral. Untuk metode hasil multilateral kurang maksimal karena ada berbagai kepentingan negara yang masuk ke dalam perjanjian.
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Švecova, Ļubova. „TAX FRAUD PHENOME: QUALIFICATION DUE TO CRIMINAL LAW IN FIELD OF VAT“. Administrative and Criminal Justice 3, Nr. 76 (30.09.2016): 29. http://dx.doi.org/10.17770/acj.v3i76.2862.
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In the present article the author has considered in a concentrated form the essence of the tax fraud phenomenon, the responsibility for which is determined by the legislation, both in administrative and criminal order – in accordance with 218 (tax avoidance) and 177 (fraud) acts. The aim of the present research is to consider the problems of tax violation, to systematize the issues related to the qualification of criminal acts in the area of taxation at establishing the fact of fraud with value added tax. The author systematized the elements of criminal acts’ compounds - fraud and tax evasion, the importance of the aspect of separating fictitious and real transactions during their classification, as well as addressed issues related to the offense ascertaining at the stage of its ending, in case of fraud with value added tax. There have been no previous investigations found on researching the phenomenon of tax fraud in Latvia through the prism of analysis of prevalence cause, types on manifestation of the phenomenon and ways of preventing and dealing with it. While researching the phenomenon of tax fraud, the author intends to examine the problem in greater details. The main conclusion, which relates to fraud with value added tax, is the fact that the Law system on Value Added Tax itself enables the unfair taxpayer to commit fraud. The lack of clear approach and criteria for the qualification of tax fraud has a negative impact on the effectiveness of preventing and dealing with this criminal act.
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VASYLCHYSHYN, Oleksandra. „FINANCIAL CRIMES IN THE FISCAL SPHERE AS A THREAT TO THE ECONOMIC SECURITY OF UKRAINE“. WORLD OF FINANCE, Nr. 1(66) (2021): 124–37. http://dx.doi.org/10.35774/sf2021.01.124.
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Introduction. Such criminogenic phenomena as shadowing and monopolization of the economy, legalization (laundering) of criminally obtained property are intensifying today in Ukraine. Recent changes in legislation and prospects for reforming fiscal and law enforcement institutions require a permanent study of the state of prevention, detection and investigation of financial crimes in the fiscal sphere. In this context, an important task is to create a single institution with appropriate functions, rights and powers. The purpose of the article is to identify real and possible risks for the formation of effective optimal directions for ensuring the economic security of Ukraine based on the analysis of the peculiarities of the processes of prevention, detection, termination, investigation and detection of financial crimes in the fiscal sphere. Methods. A number of general and special research methods were used in the study of the prevention, detection and investigation of financial crimes in the fiscal sphere, in particular: analysis, synthesis, induction, deduction, abstract-logical method and generalization method. Results. The necessity of creating a single institution for the prevention, detection and investigation of financial crimes, including in the fiscal sphere, is substantiated. Based on government statistics, the eight most popular tax avoidance schemes in Ukraine have been identified, leading to total budget losses. The structure of predicate crimes in court convictions in recent years is analyzed, and the main types of predicate crimes in the fiscal sphere are outlined. It is proved that in Ukrainian practice the number of criminal proceedings for tax evasion, brought to sentencing and prosecution decreases sharply, which indicates: the actual impunity for committing crimes in the fiscal sphere; inaction or excess of authority, improper investigation by the persons investigating these crimes, the presence of a corruption component in the pre-trial investigation; incompetence of investigators (detectives) investigating crimes in the fiscal sphere, as well as insufficient level of knowledge in the fiscal sphere of prosecutors as procedural managers. This made it possible to argue the feasibility of creating an economic security bureau. Based on the analysis of the dispositions of the articles of the Special Part of the Criminal Code of Ukraine, twelve articles have been identified that should be classified as tax crimes. Perspectives. Further research should focus on finding the best approach to addressing the issue of financial crime in the fiscal sphere, as well as to ensure the appropriate level of economic security in Ukraine.
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Lunina, Inna, Olena Bilousova und Nataliya Frolova. „TAX REFORMS FOR THE DEVELOPMENT OF FISCAL SPACE“. Baltic Journal of Economic Studies 6, Nr. 3 (05.08.2020): 48–58. http://dx.doi.org/10.30525/2256-0742/2020-6-3-48-58.
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A reduction of the tax burden on corporate income in order to stimulate drivers of economic development has become the important issue of tax reform in many countries in recent decades. Tax competition forces national governments to take well-balanced solution on increasing outward and domestic investments as well as ensuring the fiscal capacity of the budget to cope with urgent socio-economic problems under enhancing fiscal risks. The purpose of the article is to assess the impact of tax reforms, addressing reducing the corporate income tax burden, on the fiscal space and investment processes in the EU countries and Ukraine, to establish directions of improvement of the tax system in Ukraine and other transition economies in order to spur the expansion of fiscal space. The research subject covers tax policy settings that shape fiscal space development. Research methodology. In accordance with the purpose of the article, the research methods are set as follows: abstract-logical; systemic analysis; analysis and synthesis; graphical method. Findings. By summing up theoretical ideas on the issue of feasibility of cutting corporate income tax, we have arrived at the conclusion that this measure has a significant impact on the improvement of tax competitiveness of the national economy. The gain from its application is confirmed by the best practices of many European countries. The results of the tax reform in Ukraine have proved that a traditional approach to the choice of tax issues – in contrast with developed economies – do not comply with theoretical provisions on increasing the competitiveness of the national economy and fostering investments. This is conditional on the specific tax effects in Ukraine due to the restriction of the key economic freedoms (investment, financial, property rights protection and judicial effectiveness) needed for successful entrepreneurship, as well as of a high rate of corruption, which increases the costs of business activity. Such effects include, in particular, a drop of tax revenues in the short and long term while reducing the level of corporate income taxation; a high level of tax evasion, capital outflow instead of expanding investment in the national economy. It is argued that the emphasis while carrying out tax reforms and expanding fiscal space in transition economies considering the specific effects of changing corporate income tax provisions, should be made on ensuring the long-term sustainability of public finances through measures of budget adjustments aimed at avoidance shifting the existing fiscal problems on future generations; harmonization of national tax legislation with the EU regulations and prevention of tax evasion; increasing the financial capacity of enterprises by introducing targeted innovation tax incentives, which will gain higher competitiveness of the country in the world markets and as a result facilitate the growth of the country’s future revenue receipts.
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Baratashvili, Nazi, und Zaza Pharsenadze. „Importance of double taxation to increase export potential of Georgia“. Economics, ecology, socium 2, Nr. 4 (31.12.2018): 41–52. http://dx.doi.org/10.31520/2616-7107/2018.2.4-5.
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Introduction. According for future economic development of country and creation strong stable political framework is essential to improve international existing mechanism of avoiding double taxation. Double taxation avoidance system is an essential component of good business environment and is a key factor of stimulating investments. Agreements of Double taxation provide legal framework of releasing from double taxation. In spite of that, such exemption is foreseen by the internal law of different countries, international double taxation agreements provides contingency approach.
Aim and tasks. The aim of the article is to study the directions of avoiding double taxation, which contributes to the deepening of economic cooperation between countries and attracting investment. The task is to study and show the positive and negative sides of double tax treaties.
Results. One of the main factor of countries economic development is to promote export. For that every country is interested in incensement of export share per capital in foreign trade. In the article is analysed trends of development of international double taxation principles and forms. Research shows and confirms that an effective legal mechanism in Georgia is still in the process of formation in this field. Trade liberalization contributes to the creation of such flexible mechanisms, which allow developing countries receive maximal benefits from the process of world economic development. Also, Georgia received economic benefits from agreement of Avoidance of Double Taxation, which was signed all parties.
Conclusions. We have to mention that for Georgia is great challenge to increase export share per capital in European Union countries. Georgian has real ability to increase export potential in EU countries. The result of this is deep and comprehensive Free Trade Agreement (DCFTA) with the European Union and agreement of Avoidance of Double Taxation and the Prevention of Fiscal evasion (DTAA) with respect to taxes on income. It promotes to build further new trade economic cooperation between countries by safeguarding the interests of involved countries according the agreement.
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Blaudeck, Natascha, Peter Kreutzenbeck, Roland Freudl und Georg A. Sprenger. „Genetic Analysis of Pathway Specificity during Posttranslational Protein Translocation across the Escherichia coli Plasma Membrane“. Journal of Bacteriology 185, Nr. 9 (01.05.2003): 2811–19. http://dx.doi.org/10.1128/jb.185.9.2811-2819.2003.
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ABSTRACT In Escherichia coli, the SecB/SecA branch of the Sec pathway and the twin-arginine translocation (Tat) pathway represent two alternative possibilities for posttranslational translocation of proteins across the cytoplasmic membrane. Maintenance of pathway specificity was analyzed using a model precursor consisting of the mature part of the SecB-dependent maltose-binding protein (MalE) fused to the signal peptide of the Tat-dependent TorA protein. The TorA signal peptide selectively and specifically directed MalE into the Tat pathway. The characterization of a spontaneous TorA signal peptide mutant (TorA*), in which the two arginine residues in the c-region had been replaced by one leucine residue, showed that the TorA*-MalE mutant precursor had acquired the ability for efficiently using the SecB/SecA pathway. Despite the lack of the “Sec avoidance signal,” the mutant precursor was still capable of using the Tat pathway, provided that the kinetically favored Sec pathway was blocked. These results show that the h-region of the TorA signal peptide is, in principle, sufficiently hydrophobic for Sec-dependent protein translocation, and therefore, the positively charged amino acid residues in the c-region represent a major determinant for Tat pathway specificity. Tat-dependent export of TorA-MalE was significantly slower in the presence of SecB than in its absence, showing that SecB can bind to this precursor despite the presence of the Sec avoidance signal in the c-region of the TorA signal peptide, strongly suggesting that the function of the Sec avoidance signal is not the prevention of SecB binding; rather, it must be exerted at a later step in the Sec pathway.
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Bazov, Viktor. „Controlled foreign companies (CFC/КІК): concept and principles of taxation“. Slovo of the National School of Judges of Ukraine, Nr. 4(33) (15.03.2021): 110–19. http://dx.doi.org/10.37566/2707-6849-2020-4(33)-9.
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The article is sanctified to the decision of concept and principles of taxation of the controlled foreign companies. Basic ideas that were fixed in basis of judicial doctrine of the controlled foreign companies are investigational. It will be that an input in the tax law of rules of taxation of the controlled foreign companies is related to the necessity of implementation at national level of step of 3 Plans of actions of BEPS «Development of effective rules of taxation of the controlled foreign companies (CFC)». Marked, that with the aim of input of international standards of tax control for all participants of international trade, implementation of requirements of MLI of Convention and norms, envisaged by Plan of counteraction to practices of washing out of taxable base and leading out of profit from under taxation, reformation of institute of financial responsibility and improvement of procedure of administration of taxes and collections passed an act Verhovna Rada of Ukraine from January, 16, 2020 № 466, - IX «About making alteration in the Internal revenue code of Ukraine relating to perfection of administration of tax, removal technical and logical inconsistency in tax law», that envisage input rules : а) control after transfer pricing (Steps 8-10, 13); b) taxation of the controlled foreign companies (Step 3); c) limitation of charges is on financial operations with the constrained persons (Step 4); d) prevention by abuse with application of agreements on avoidance of double taxation (Step 5). Attention applies on that among unplanned earlier steps implementation not only of minimum standard of Plan of actions of BEPS is envisaged in this Law, id est four his steps, and realization of eight steps, in particular and to the step of 3 Plans of actions of BEPS «Development of effective rules of taxation of the controlled foreign companies (CFC)». It is underlined that as an input of Plan of actions of BEPS is considered world tax revolution, implementation in the Internal revenue code of Ukraine of step of 3 Plans of actions of BEPS «Development of effective rules of taxation of the controlled foreign companies (CFC)» will allow to provide additional receivabless in the State budget of Ukraine due to the increase of transparency of international transactions of subjects of menage. Marked, that the input of effective rules of taxation of the controlled foreign companies will prevent the use of aggressive charts of the tax planning, will assist the input of international standards of tax control for all participants of international trade, will perfect procedure of administration of taxes and collections, and also will assist the observance of principle of justice of taxation. The mechanism of decision of spores and judicial practice are analysed in the field of legal relationships, foreign companies related to taxation of controlled. Keywords:international taxation, controlled foreign companies, principles of taxation, judicial practice.
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Grona, Andrew Vadimovich. „WAYS TOWARDS ADVANCED AUTOMATIC MEASURES TO PREVENT VAT EVASION“. UKRAINIAN ASSEMBLY OF DOCTORS OF SCIENCES IN PUBLIC ADMINISTRATION 1, Nr. 11 (24.01.2018): 102–18. http://dx.doi.org/10.31618/vadnd.v1i11.18.
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This paper intends to bring a view on possible measures, which the Cabinet of Ministers and Finance Department of Ukraine are authorized to implement. These measures concern introducing new criteria for evaluating the level of risks, sufficient for stopping a registration of tax invoices/adjustment calculations, depending on a kind of the stated goods’ issue. Both the criteria and implementation of those are based on the information, received from an au- tomated VAT payers’ inventory accounting system, necessary for creationas a component of VAT electronic administration system. The paper brings a view on measures, intended to automate a processof reviewing tax payers’ written expla- nations by the SFS committee, established in accord to FDU’s order # 566 on 13.06.2017. In addition, some automatic measures to prevent realizing the “twist- ing” operations have been proposed in the paper. It was noted that the procedure for stopping the registration of risky tax invoices was introduced as a means of automatically preventing such a widespread VAT avoidance scheme as a “twist” for all goods, and not just for fuel. In this article, under the risky tax billing/ adjustment calculations, it is proposed to understand such tax invoices/adjust- ments calculations that satisfy the approved criteria of the Ministry of Finance to assess the degree of risk sufficient to stop their registration. It is noted that the principle of indiscretion has already been established in Ukraine. It is estab- lished prematurely, since it is not yet backed up by effective automatic measures to prevent VAT deviations. The real implementation of this principle is one of the key points in improving the investment climate and implementing economic re- forms in Ukraine. It will sharply increase the level of freedom of doing business in Ukraine, will open the way for an automatic VAT refund procedure and deprive enterprises of unreasonable checks that are carried out in connection with the detection of tax breaches by their counterparties (and, more often, counteragents of their counterparties).
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Grona, Andrew Vadimovich. „WAYS TOWARDS ADVANCED AUTOMATIC MEASURES TO PREVENT VAT EVASION“. UKRAINIAN ASSEMBLY OF DOCTORS OF SCIENCES IN PUBLIC ADMINISTRATION 1, Nr. 12 (14.02.2018): 102–18. http://dx.doi.org/10.31618/vadnd.v1i12.53.
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This paper intends to bring a view on possible measures, which the Cabinet of Ministers and Finance Department of Ukraine are authorized to implement. These measures concern introducing new criteria for evaluating the level of risks, sufficient for stopping a registration of tax invoices/adjustment calculations, depending on a kind of the stated goods’ issue. Both the criteria and implementation of those are based on the information, received from an automated VAT payers’ inventory accounting system, necessary for creationas a component of VAT electronic administration system. The paper brings a view on measures, intended to automate a processof reviewing tax payers’ written explanations by the SFS committee, established in accord to FDU’s order # 566 on 13.06.2017. In addition, some automatic measures to prevent realizing the “twisting” operations have been proposed in the paper. It was noted that the procedure for stopping the registration of risky tax invoices was introduced as a means of automatically preventing such a widespread VAT avoidance scheme as a “twist” for all goods, and not just for fuel. In this article, under the risky tax billing/ adjustment calculations, it is proposed to understand such tax invoices/adjustments calculations that satisfy the approved criteria of the Ministry of Finance to assess the degree of risk sufficient to stop their registration. It is noted that the principle of indiscretion has already been established in Ukraine. It is established prematurely, since it is not yet backed up by effective automatic measures to prevent VAT deviations. The real implementation of this principle is one of the key points in improving the investment climate and implementing economic reforms in Ukraine. It will sharply increase the level of freedom of doing business in Ukraine, will open the way for an automatic VAT refund procedure and deprive enterprises of unreasonable checks that are carried out in connection with the detection of tax breaches by their counterparties (and, more often, counteragents of their counterparties).
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Vamvakas, Eleftherios C., und Morris A. Blajchman. „Transfusion-related mortality: the ongoing risks of allogeneic blood transfusion and the available strategies for their prevention“. Blood 113, Nr. 15 (09.04.2009): 3406–17. http://dx.doi.org/10.1182/blood-2008-10-167643.
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Abstract As the risks of allogeneic blood transfusion (ABT)–transmitted viruses were reduced to exceedingly low levels in the US, transfusion-related acute lung injury (TRALI), hemolytic transfusion reactions (HTRs), and transfusion-associated sepsis (TAS) emerged as the leading causes of ABT-related deaths. Since 2004, preventive measures for TRALI and TAS have been implemented, but their implementation remains incomplete. Infectious causes of ABT-related deaths currently account for less than 15% of all transfusion-related mortality, but the possibility remains that a new transfusion-transmitted agent causing a fatal infectious disease may emerge in the future. Aside from these established complications of ABT, randomized controlled trials comparing recipients of non–white blood cell (WBC)–reduced versus WBC-reduced blood components in cardiac surgery have documented increased mortality in association with the use of non-WBC–reduced ABT. ABT-related mortality can thus be further reduced by universally applying the policies of avoiding prospective donors alloimmunized to WBC antigens from donating plasma products, adopting strategies to prevent HTRs, WBC-reducing components transfused to patients undergoing cardiac surgery, reducing exposure to allogeneic donors through conservative transfusion guidelines and avoidance of product pooling, and implementing pathogen-reduction technologies to address the residual risk of TAS as well as the potential risk of the next transfusion-transmitted agent to emerge in the foreseeable future.
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Iryna, HLADIY. „TRANSFER PRICING OF TRANSNATIONAL CORPORATIONS“. Foreign trade: economics, finance, law 116, Nr. 3 (15.06.2021): 85–97. http://dx.doi.org/10.31617/zt.knute.2021(116)08.
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Background. In the context of globalization, transnational corporations have turned into highly concentrated points of the world economy and the principal markets for goods and services. It is under such conditions that a comprehensive research of the pricing system within the framework of their activities is relevant. Analysis of recent research and publications has revealed that the process of setting prices for products within their activities in different countries and the development of innovations in domestic legislation require in-depth study. The aim of the article was to study possible transfer pricing systems for TNCs in order to eliminate risks when calculating the exact cost of products and avoid possible situations of non-payment of due taxes. Materials and methods. A set of general scientific methods of cognition is applied: inductive, deductive, system analysis, theoretical generalization, formal-logical, analysis and synthesis. Results. The transfer pricing system is becoming the key direction in the process of planning and profit maximization. The methods of setting the transfer price are legally enshrined in the current Tax Code of Ukraine. However, the use of these methods is a top priority for checking compliance with the «arm’s length»principle. It is determined that in order to comply with this principle, it is necessary to compare controlled and uncontrolled transactions, based on the criterion of tax benefits, as well as to analyse all the advantages and disadvantages that they create. Conclusion. The issue of proper transfer pricing plays a leading role in the export or import of goods. Particular attention should be paid to the sources of information indicated by taxpayers and used in order to ensure compliance with the requirements for justification in the documentation on transfer pricing compliance with the conditions of controlled transactions with the arm’s length principle. Prospects for further research are to provide practical recommendations for compliance of the legal and regulatory framework for transfer pricing with the requirements of the world economy in the direction of preventing the implementation of tax avoidance schemes.
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Blayney, Douglas W., Ramon Mohanlal und Lan Huang. „Protective-2 (BPI-2358-106): A Confirmatory Trial to Demonstrate Superiority of the Plinabulin+Pegfilgrastim (Plin/Peg) Combination Versus Standard of Care Pegfilgrastim for the Prevention of Chemotherapy-Induced Neutropenia (CIN) in Breast Cancer (BC) Patients (pts)“. Blood 136, Supplement 1 (05.11.2020): 16. http://dx.doi.org/10.1182/blood-2020-141110.
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Introduction. BC is a potentially curable cancer condition, with more favorable outcomes with avoidance of CIN. Peg is the standard of care for the prevention of CIN, but does not fully prevent CIN (Masuda 2015). Plin is a novel, small molecule, non-G-CSF agent, given as a single dose per cycle, by 30 min IV infusion, 30 min after Chemotherapy (Chemo), on the same day of Chemo. In contrast to Peg, Plin does not cause bone pain or thrombocytopenia (Blayney JAMA Onc in press). The mechanism of action (MoA) of Plin exerts its CIN preventive effects predominantly in week 1 of the cycle, whereas Peg primarily in week 2. This was the rationale to combine these two agents, to obtain superior CIN protection throughout the entire cycle (Blayney ASCO 2019). Data from Phase (Ph) 2 portion of PROTECTIVE-2 (NCT0329457) with the Plin/Peg combination demonstrated superiority in CIN protection vs Peg alone, with a favorable safety/tolerability profile (Blayney, St Gallen 2019). Additionally, the addition of Plin to Peg almost eradicated the Peg-induced bone pain. The Ph 3 portion of PROTECTIVE-2 aims to confirm superiority of the Plin/Peg combination vs Peg standard of care for avoidance of CIN and Bone Pain-prevention. Trial Design PROTECTIVE-2 is a global, multicenter, randomized, double-blind Study to Evaluate Plin 40 mg + Peg 6mg (Arm 1) versus Peg 6mg + Placebo (Arm 2) in preventing Severe Neutropenia (defined as Absolute Neutrophil Count (ANC) of <0.5×10E9/L) in early stage (Stage I and II) and Stage III BC (node positive or node negative with a high risk of recurrence) pts with ECOG status 0 or 1 (target of approximately n=222 pts) receiving myelosuppressive Chemo with Docetaxel (75 mg/m2), Doxorubicin (50 mg/m2), and Cyclophosphamide (500 mg/m2) (TAC). A non-binding Interim Analysis was a planned at approximately n=100 pts completing Cycle 1. TAC and Plin were given on Day (D) 1 and Peg on D2. ANC (Covance Central Laboratory) was assessed before and after during Cycle 1 on D 1, 2, 3, 6, 7, 8, 9, 10, 11, 12, 13, and 15. Bone Pain was assessed by a validated at regular timepoints in Cycle 1 with a validated PRO questionnaire. The Primary objective was to compare the percentage of pts with a Duration of Severe Neutropenia (DSN) of 0 days in treatment Cycle 1 between the Plin/Peg vs Peg alone. Secondary objectives in Cycle 1 included mean DSN, mean ANC NADIR, average change in Bone Pain from baseline, the rate of composite risk (infection, FN, hospitalization, significant disability, life threatening and death), and over 4 Cycles, the percentage of patients with Relative Dose Intensity (RDI) < 85%. Following the pre-planned Interim Analysis, the DSMB recommended the trial to continue without modifications. Current Status: Patient accrual has been completed. Disclosures Blayney: BeyondSpring Pharma: Other: Research Funding to Institution. Mohanlal:BeyondSpring Pharma: Current Employment, Current equity holder in publicly-traded company. Huang:BeyondSpring Pharma: Current Employment, Current equity holder in publicly-traded company.
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Kapitsa, L. M. „SHADOW GLOBALIZATION“. MGIMO Review of International Relations, Nr. 3(36) (28.06.2014): 69–81. http://dx.doi.org/10.24833/2071-8160-2014-3-36-69-81.
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The article reviews some development trends brought about by globalization, particularly, a growing tax evasion and tax avoidance, an expansion of illicit financial flows and the proliferation of a global criminal network. The author draws attention to some new phenomena, particularly, cosmopolitanization of some parts of national elites and a deepening divide between national interests and the private interests of elites as a consequence of financial globalization. Modern mass media, both Russian and foreign, tend to interpret globalization processes exclusively from the position of conformism, and for some of the researchers globalization became the "sacred cow", which one may only worship. Critical analysis of the processes associated with globalization is given a hostile reception. In response to criticism of globalization, one can hear the very same argument: "globalization in inevitable!" Such a state of affairs, the very least, causes perplexity. Some of the world development trends been observed over the past years raise serious concerns about the security and welfare of the peoples of the world. One of such trends has been the globalization of shadow economic activities. Methods of fight against the criminal economy been applied in international practice can be grouped into: 1) punitive enforcement (or criminal-legal) methods) and 2) socio-economic methods. As the results of various research works evidence punitive enforcement methods not supported by socio-economic measures not effective enough. Toughening the control over criminal economic activities in the absence of preventive and corrective actions aiming to neutralize institutional, social and other stimuli facilitating criminalization of economic activities can result in large losses of financial assets in the form of mass capital flight
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Ohlsson, Henry. „Tax avoidance“. L’annuaire du Collège de France, Nr. 109 (01.03.2010): 1055–57. http://dx.doi.org/10.4000/annuaire-cdf.407.
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Kopkin, Nolan. „Tax Avoidance“. Journal of Sports Economics 13, Nr. 6 (30.06.2011): 571–602. http://dx.doi.org/10.1177/1527002511412194.
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Park, JongIl, und KyuAn Jeon. „Tax Avoidance and Tax Uncertainty“. korean journal of taxation research 36, Nr. 1 (31.03.2019): 9–54. http://dx.doi.org/10.35850/kjtr.36.1.01.
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Lee, Hyun Joo, und Kyu Eon Jung. „Tax Smoothing and Tax Avoidance“. korean journal of taxation research 35, Nr. 3 (30.09.2018): 9–34. http://dx.doi.org/10.35850/kjtr.35.3.01.
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Ismawati, Yeni Indah, und Novrida Qudsi Lutfillah. „DETERMINANT TAX AVOIDANCE“. Research In Management and Accounting 2, Nr. 2 (Dezember 2019): 76–86. http://dx.doi.org/10.33508/rima.v2i2.2604.
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Sharife, Khadija. „Jackpot Tax Avoidance“. World Policy Journal 34, Nr. 3 (2017): 99–104. http://dx.doi.org/10.1215/07402775-4280076.
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Guenther, David A., Ryan J. Wilson und Kaishu Wu. „Tax Uncertainty and Incremental Tax Avoidance“. Accounting Review 94, Nr. 2 (01.07.2018): 229–47. http://dx.doi.org/10.2308/accr-52194.
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ABSTRACT We investigate whether tax avoidance becomes more uncertain as the rate of tax avoidance increases. We estimate a system of equations to demonstrate that as firms' pretax income increases, each additional dollar of potential tax results, on average, in 32.8 cents of tax avoided, which we refer to as incremental tax avoidance. Of the incremental tax avoided, 1.4 cents represent additions to the reserve for uncertain tax benefits (UTB reserve), or 4.3 percent of the total incremental tax avoided. We then partition sample firms into groups that prior research suggests engage in higher rates of tax avoidance, and examine the amount of incremental tax avoidance that results in additions to the UTB reserve. Results demonstrate that the percentage of incremental tax avoidance reflecting additions to UTB reserve is not larger for groups engaging in higher rates of tax avoidance, suggesting higher rates of tax avoidance may not be more uncertain. JEL Classifications: H26; M41; M48.
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Kaikita, Koichi, Kazuya Hosokawa, Jeffrey R. Dahlen und Kenichi Tsujita. „Total Thrombus-Formation Analysis System (T-TAS): Clinical Application of Quantitative Analysis of Thrombus Formation in Cardiovascular Disease“. Thrombosis and Haemostasis 119, Nr. 10 (22.07.2019): 1554–62. http://dx.doi.org/10.1055/s-0039-1693411.
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AbstractVarious antithrombotic agents are clinically used to inhibit the cascade of arterial or venous thrombosis in cardiovascular diseases. Dual antiplatelet therapy with aspirin and P2Y12 inhibitors is prescribed in patients with coronary artery disease (CAD) undergoing percutaneous coronary intervention (PCI). Direct oral anticoagulants (DOACs) are widely used for the prevention or treatment of thromboembolism in patients with atrial fibrillation (AF) and venous thromboembolism. However, there has been no definitive tool to simultaneously monitor the antithrombotic effects of these drugs. The Total Thrombus-Formation Analysis System (T-TAS), a microchip-based flow chamber system that mimics in vivo conditions for evaluating whole blood thrombogenicity, was developed for the quantitative analysis of thrombus formation in whole blood specimens. The utility of T-TAS has been evaluated in CAD patients treated with antiplatelet therapies. The T-TAS PL chip area under the flow pressure curve (AUC) accurately assesses primary hemostasis and is sensitive to the therapeutic effects of various antiplatelet therapies. In addition, low AUC results are a significant predictor of periprocedural bleeding events in CAD patients undergoing PCI. The T-TAS AR chip AUC result is useful for assessing the efficacy of DOACs and warfarin in AF patients undergoing catheter ablation, and it is also a potential independent predictor of periprocedural bleeding events and avoidance of thrombosis in patients having undergone total knee arthroplasty. In conclusion, T-TAS is a useful index for evaluating the total antithrombotic effects of combination antithrombotic agents in patients with various cardiovascular diseases.
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Ko, Jong Kwon, und Hee Jin Park. „Tax Haven Utilization and Tax Avoidance“. Korean Accounting Journal 26, Nr. 2 (30.04.2017): 83–115. http://dx.doi.org/10.24056/kaj.2017.03.002.
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Park, Si－Hun, und Kap－Soon Kim. „Incremental Tax Avoidance and Tax Risk“. Journal of Taxation and Accounting 20, Nr. 6 (31.12.2019): 191–218. http://dx.doi.org/10.35850/kjta.20.6.08.
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안동일 und KeeJoon Seok. „The Influence of Tax Avoidance Factors on Propensity of Tax Avoidance－Focused Capital Gain Tax－“. Tax Accounting Research ll, Nr. 45 (September 2015): 105–28. http://dx.doi.org/10.35349/tar.2015..45.006.
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Boone, Jeff P., Inder K. Khurana und K. K. Raman. „Religiosity and Tax Avoidance“. Journal of the American Taxation Association 35, Nr. 1 (01.10.2012): 53–84. http://dx.doi.org/10.2308/atax-50341.
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ABSTRACT: In this paper, we examine religiosity as one determinant of tax avoidance by corporate and individual taxpayers. Prior research suggests a relation between religiosity and risk aversion. Because aggressive tax avoidance strategies involve significant uncertainty and possible penalties and damage to reputation, we predict that higher levels of religiosity are associated with less aggressive (i.e., less risky) tax positions. Consistent with this prediction, we find that firms headquartered in more religious U.S. counties are less likely to avoid taxes. We also find that religiosity is consistently associated with lower tax avoidance by individual taxpayers, as measured by underreported income. These results hold after controlling for several firm-level, as well as county-level, demographic characteristics identified in prior research as affecting tax avoidance by corporate and/or individual taxpayers. We conclude that religiosity is a significant determinant of tax avoidance by corporate and individual taxpayers.
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Alarie, Benjamin. „TREBILCOCK ON TAX AVOIDANCE“. University of Toronto Law Journal 60, Nr. 2 (April 2010): 623–42. http://dx.doi.org/10.3138/utlj.60.2.623.
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Mansi, Sattar, Jianping Qi und Han Shi. „Advertising and tax avoidance“. Review of Quantitative Finance and Accounting 54, Nr. 2 (06.03.2019): 479–516. http://dx.doi.org/10.1007/s11156-019-00796-6.
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