TNC Tax Planning Based on a Risk-Oriented Approach in the Conditions of the Beps Project and Economy Digitalization

The article investigates the peculiarities of the transnational corporations (TNC) tax planning in the context of the base erosion and profit shifting (BEPS) project and economic digitalization. The authors conducted an analysis of the rules that regulate the application of risk management in TNC activities, and they justified the feasibility of using SWIFT and matrix methods for assessing tax risks in the process of TNC tax planning. A model of TNC tax planning in the context of economy digitalization and BEPS project, which allowed for increased tax planning effectiveness by obtaining objective and sufficient information for the construction of possible scenarios of the companies' operations, is proposed in the article. The model includes stages of the tax planning process, namely: tax landscape analysis for countries of registration, countries of digital presence, and international taxation rules; constructing a tax risk trigger chain for the company; assessing the probability and impact of tax risks; identifying and selecting tax risk management options; integration of tax risk management in the business scenario. The conducted research allowed us to predict what would happen if tax rates, conditions for determining the object of taxation, or other taxation conditions in the TNC’s country of registration or presence changed. In the article, it was proposed to use the results of comparing corporate performance indicators (the rate of change in profit, return on assets, return on capital, return on sales) and indicators characterizing tax consequences (the rate of change in tax liabilities) as criteria for selecting tax risk management options for TNC. The authors defined the mechanism for choosing the tax risk management methods in the context of the economic digitalization and the particular BEPS project, which allowed conducting the real-time control not only by TNC, but also by tax control bodies, auditors, financial consultants, and representatives of international organizations, simplified communication between them, and reduced subjectivity when making any decisions.