In global and national practice, schemes have increasingly emerged where payments for the use of intellectual property that are not subject to withholding tax lead to an understatement/erosion of the tax base, the transfer of high-value intellectual property results to low-tax jurisdictions, which, accordingly, leads to problems with tax control. When administering intangible assets, tax authorities face a non-trivial task: to determine whether the level of payments for the use of intellectual property results, including digital assets and property, corresponds to the level of market prices. The chapter considers theoretical issues and problems of administering transactions with intangible assets, including digital ones. The purpose of the study is to offer the scientific community hypothetically relevant areas of tax administration of intangible assets and to reveal the prospects for using digital assets in order to minimize tax risks in payment transactions. Changes in the international tax system of the current decade and in the future may affect how countries should provide effective financial support to innovation. The changing global situation with corporate taxation and international tax reform, the updated tax policy of Russia is one of the factors that will determine the future effectiveness of the use of tax incentives to promote innovation in business and administration. The economic and general scientific methods used in the study: classification, systems approach, analysis and synthesis, comparison, induction, systematization, allowed us to achieve the stated goal. The results of the scientific research in the proposed publication made it possible to focus on the need for international uniformity of the definitions of “intangible assets” and “digital financial assets”. To consider the impact of the tax component on the specifics of administering these research objects. Analysis of international experience in this area made it possible to propose the introduction of a nexus approach (based on calculating qualified profit using the coefficient of essential connection)) in solving the problems of reducing aggressive tax planning for transactions with intangible assets using digital financial assets. The philosophical and economic meaning of the systemonomic approach in solving the problems of tax evasion of intangible assets is revealed. An analysis of the taxation of digital financial assets was conducted.

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Features of Tax Administration of Intangible Assets and the Role of Digital Assets in Reducing Tax Risks: A Systemonomic Approach in Tax Policy

  • Irina Zhuravleva

摘要

In global and national practice, schemes have increasingly emerged where payments for the use of intellectual property that are not subject to withholding tax lead to an understatement/erosion of the tax base, the transfer of high-value intellectual property results to low-tax jurisdictions, which, accordingly, leads to problems with tax control. When administering intangible assets, tax authorities face a non-trivial task: to determine whether the level of payments for the use of intellectual property results, including digital assets and property, corresponds to the level of market prices. The chapter considers theoretical issues and problems of administering transactions with intangible assets, including digital ones. The purpose of the study is to offer the scientific community hypothetically relevant areas of tax administration of intangible assets and to reveal the prospects for using digital assets in order to minimize tax risks in payment transactions. Changes in the international tax system of the current decade and in the future may affect how countries should provide effective financial support to innovation. The changing global situation with corporate taxation and international tax reform, the updated tax policy of Russia is one of the factors that will determine the future effectiveness of the use of tax incentives to promote innovation in business and administration. The economic and general scientific methods used in the study: classification, systems approach, analysis and synthesis, comparison, induction, systematization, allowed us to achieve the stated goal. The results of the scientific research in the proposed publication made it possible to focus on the need for international uniformity of the definitions of “intangible assets” and “digital financial assets”. To consider the impact of the tax component on the specifics of administering these research objects. Analysis of international experience in this area made it possible to propose the introduction of a nexus approach (based on calculating qualified profit using the coefficient of essential connection)) in solving the problems of reducing aggressive tax planning for transactions with intangible assets using digital financial assets. The philosophical and economic meaning of the systemonomic approach in solving the problems of tax evasion of intangible assets is revealed. An analysis of the taxation of digital financial assets was conducted.