Історія становлення концепції контрольованої іноземної компанії у міжнародному оподаткуванні
Bibliographic record
Abstract
In the article, the author examines the history of the concept of controlled foreign companies in international taxation. It is stated that the consistent introduction of the rules for controlled foreign companies demonstrates the desire of states to minimize tax risks in tax planning and to introduce rules which make it impossible to optimize the tax burden and, as a result, to avoid paying taxes in the country of residence of the beneficial owners of income. It is established that historically, the rules for taxation of controlled foreign companies have existed in the legislation of foreign countries since 1962, when they were introduced in the United States of America. The historical background to the taxation of controlled foreign companies was that after the end of World War II, the political and economic measures introduced in the United States became a powerful incentive for the global expansion of American companies. This contributed to the active establishment of enterprises in countries with favorable tax conditions, where the level of taxation was minimal. As a result, a significant portion of financial resources was concentrated in these jurisdictions, which made it difficult for the United States of America to tax them and control capital flows. It is noted that after the concept of controlled foreign companies was established in the United States of America, similar rules were introduced in most developed countries of the world, for example, in Germany, Canada, Japan, France, the United Kingdom of Great Britain and Ireland, and Spain. In this article, the author examines in detail the history of the concept of a controlled foreign company in the United States of America and Germany, and also analyzes the legislation of these countries. The author compares the respective taxation rules for controlled foreign companies in these countries and in Ukraine, where such rules for controlled foreign companies have been in force only since 2022. It is concluded that Ukraine has a long way to go to develop an effective domestic model of taxation of a controlled foreign company, but the experience of the United States of America and Germany in this context may be useful.
Fetched live from OpenAlex and de-inverted. Abstracts are not stored in this database: the inverted indexes are 8.6 GB of the frame’s 9.3 GB of text, and the host has 13 GB free.
How this classification was reachedexpand
Full frame distilled prediction
Teacher imitationNot calibrated prevalence, not ground truth. Human validation pending. Learned from the 10,348 direct Codex labels and 10,348 direct Gemma labels. Candidate is the union of thresholded teacher heads; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels or direct frontier model labels.
Codex and Gemma teacher scores by category
| Category | Codex | Gemma |
|---|---|---|
| Metaresearch | 0.002 | 0.001 |
| Meta-epidemiology (narrow) | 0.000 | 0.000 |
| Meta-epidemiology (broad) | 0.001 | 0.000 |
| Bibliometrics | 0.001 | 0.003 |
| Science and technology studies | 0.001 | 0.001 |
| Scholarly communication | 0.001 | 0.001 |
| Open science | 0.001 | 0.000 |
| Research integrity | 0.000 | 0.000 |
| Insufficient payload (model declined to judge) | 0.003 | 0.001 |
Machine scores (provisional)
The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.
Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.
score_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from itClassification
machine, unvalidatedMachine predicted; both teacher heads agree on what is shown here.
How this classification was reached, model by model and score by score, is at the end of the page under "How this classification was reached".