Контрольовані операції у сфері зовнішньоекономічної діяльності: сучасний стан оподаткування та облікового забезпечення
Controlled Transactions in the Sphere of Foreign Trade Activity: Current State of Taxation and Accounting Support

Summary/Abstract: The article is dedicated to the research of the current state of the controlled transaction in the field of foreign trade activity accounting support and taxation. The following types of controlled transactions were analyzed – transactions with non-residents – related parties, deals on goods purchase and sell with commissions agents, transactions with non-residents, which do not pay profit tax (corporate tax), transactions between non-resident and its permanent representation in Ukraine. The definition of transactions as controlled ones when the certain conditions are fulfilled, particularly - when the year income and the sum of such transactions exceed the limits. The term of the arm’s length principle was defined for the purpose of profit tax calculation. Pointed out types of tax differences, which appear in the field of foreign trade activity.The research of controlled transactions in the field of foreign trade activity accounting support and taxation demonstrates severe burden for accountants to make reports for controlling authorities. Implementation of some subaccounts for transactions with non-residents were recommended to improve accounting support. Implementation of these subaccounts will make possible to summarize information on controlled transactions to calculate differences to define the tax profit object.The above mentioned necessity to afford the legal right to choose a method of price calculation for profit tax payer to define whether terms of controlled transaction meet the arm’s length principle or not, without additional approval of tax authority. The conclusion that it is necessary to have the completed controlled transactions report when profit tax declaration is filing was made while analyzing the method of making annex TTs to profit tax declaration and controlled transactions report, in spite of the fact that time limitation of filing the last one is mush later. The necessity of controlled transaction report cancellation was demonstrated. The necessity to improve the method of controlled operations pricing preliminary approval with tax authorities, instead of existing method, was demonstrated along with necessity to develop the procedure of tax payers administrative and court appeal of pricing preliminary approval results by tax authorities.

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