Organization of taxation and customs control of controlled foreign companies in the system of financial regulation

Abstract

. Introduction. The article examines modern approaches to the taxation of profits of controlled foreign companies (CFCs) and the improvement of customs control in Ukraine within the context of financial regulation. It outlines the regulatory framework for the introduction of CFC rules consistent with the BEPS Plan and analyzes the reporting requirements for controlling persons. Purpose. The purpose of the study is to analyse the organisation of controlled foreign company (CFC) taxation and customs control in Ukraine, to identify the interrelations between tax and customs control measures, and to determine priority directions for improving the digital infrastructure for tax data exchange within the framework of financial regulation. Materials and methods: The study is based on an analysis of: the regulatory and legal framework of Ukraine; international BEPS and CRS standards; scientific works by Ukrainian and foreign authors; tax and customs control practices. Methods: comparative, systematic, analytical and institutional approaches; statistical analysis of post-customs audit results; assessment of digital infrastructure development priorities through the Decision Support System (DSS) ‘Decision Making Helper’. Results. The peculiarities of customs control under conditions of European integration and martial law are highlighted, with emphasis on risk-based methods, post-clearance audit, and combating shadow schemes. Innovations in tax and customs control are compared to identify synergies in countering tax evasion and the movement of illegal goods. The results of the post-audit implementation (violations detected in 72% of audited declarations) are presented, and the conditions under which CFC profits are exempt from taxation are analyzed. The findings confirm that the integrated combination of control mechanisms over financial flows (through CFCs) and the movement of goods (through customs authorities) enhances the efficiency of the state’s financial regulation system.