Melnik Y. Legal regulation of tax planning of international corporations

Українська версія

Thesis for the degree of Doctor of Philosophy (PhD)

State registration number


Applicant for


  • 081 - Право. Право


Specialized Academic Board

ДФ 26.006.001

Kyiv National Economics University named after Vadym Hetman


In the dissertation, it is determined that the main prerequisites for the development of tax planning of international corporations include international tax competition; the emergence and dissemination of tax advice low cost to create tax planning schemes; imperfection of national tax planning regulation systems. It is noted that according to the international nature of tax planning, the effective regulation of this process is impossible without coordination of the world community. It is noted that, along with the forms of tax planning identified by scientists – individual, corporate, current and strategic – it is also advisable to distinguish independent (that is carried out by the taxpayer without third parties) and delegated (which is carried out with the help of tax consultants), that is associated with a significant role tax consultants in the process of developing tent planning. It is noted that one of the simplest tax planning schemes for international corporations is the choice of place of registration of separate structural units, taking into account the characteristics of alternative tax jurisdictions. It was revealed that a common scheme is also an artificial avoidance of the status of a permanent establishment for tax purposes, which allows a parent company registered in low-tax jurisdictions to pay taxes at the place of its tax residency. It is argued that the Ukrainian legislation regulating the legal framework for the implementation of tax planning is actively developing.


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