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Legal regulation of controlled foreign companies in Ukraine from the perspective of their impact on the fight against aggressive tax planning

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Legal regulation of controlled foreign companies aims to combat aggressive tax planning in Ukraine.
The article identifies ambiguities in criteria for actual control, creating legal uncertainty for taxpayers.
Tax incentives based on OECD recommendations may unintentionally facilitate aggressive tax planning strategies.
International treaties on double taxation contribute to potential loopholes that allow profit shifting to offshores.

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Analysis reveals the effects of controlled foreign companies rules on tax evasion in Ukraine, highlighting potential issues with legal uncertainties.

V. Y. Smerdov (2025) studied this question.

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Analysis reveals the effects of controlled foreign companies rules on tax evasion in Ukraine, highlighting potential issues with legal uncertainties.