Fiscal goals of regulating the activities of the institute of controlled foreign companies in the digital economy

At the OECD level, within the framework of taxation, relevant documents that directly concern the procedure for enhancing interaction and cooperation among its member states are being developed. The most important ones include the development of recommendations in the field of taxation of controlled foreign companies, including the study of current aspects in the event of a conflict between the provisions on controlled foreign companies and the concluded double taxation treaties. Meanwhile, in the study of the formation of the institute of controlled companies with regard to the manner of their formation and use of modern forms and methods of administrative control and tax liability, it is important to study actions in the sphere of international tax law. However, the emerging problems in this sphere are relevant, since, at the level of national legislation of each state, there are both objective and subjective factors that directly affect the formation of law enforcement practice on controlled foreign companies, with regard to a lack of scientific information in the context of national law. Therefore, in terms of improvement of the tax legislation of countries with developing economies that are reforming the institution of controlled foreign companies and supplementing them with new provisions which cover the basic aspects of the formation of taxation of controlled foreign companies in the digital economy, it is important to mention the urgent measures aimed at improving them, including ways of implementation and modernization of the rules and procedure for determining the profits of controlled foreign companies in terms of clarifying the list of passive taxes, as well as the composition of costs of such companies.