Звітування в розрізі країн: належне використання та конфіденційність при автоматичному обміні інформацією

One of the most important aspects of the implementation of BEPS Action 13 (Action plan BEPS - Base erosion and Profit Shifting) into the national legislation of the member countries of the Organization for Economic Co-operation and Development (OECD) and countries that have joined the BEPS Action plan, is ensuring confidentiality and appropriate use of information contained in Country-by-Сountry reporting of the international group of companies. These issues become especially relevant in the context of the introduction of international automatic exchange of tax information which allows the tax authorities of member countries to obtain all necessary information on income and accrued taxes, and identify cases of tax base erosion and tax evasion. The article proposes approaches to ensure the necessary level of effective protection of confidentiality (in particular: legislative, organizational, technical and personnel). It is determined that further work should be aimed at establishing institutional support for the administration of protection, confidentiality and proper use of tax information, that is subject to exchange, in accordance with the requirements of the Convention on Mutual Administrative Assistance in Tax Matters. Keywords: OECD, BEPS, proper use of information, information protection, confidentiality, automatic exchange of tax information, Country-by-Country reports