Restricting Profit Concealment Through Foreign Structures: Institutional Measures for Tax Transparency in Uzbekistan
Keywords:
foreign-controlled entity, tax evasion, profit concealment, tax transparency, beneficial ownership, CFC regulations, Uzbekistan tax reforms, OECD BEPS, AEOI, institutional tax oversightAbstract
This article examines institutional and legal mechanisms for preventing tax base erosion caused by undisclosed profits through foreign legal structures controlled by domestic taxpayers. It analyzes global experiences with anti-avoidance measures—especially the regulation of foreign-controlled entities—and assesses how such frameworks can be adapted to Uzbekistan. Particular attention is given to the role of digital oversight, international data exchange systems, and beneficial ownership declarations. The study proposes regulatory steps for Uzbekistan to strengthen its fiscal transparency infrastructure and integrate CFC-related tax controls with global standards.
References
1. Musgrave, R.A. (1989). Public Finance in Theory and Practice. New York: McGraw-Hill.
2. Stiglitz, J.E. (2000). Economics of the Public Sector. New York: W.W. Norton & Co.
3. OECD (2015). BEPS Action 3 and Action 12 Reports. Paris: OECD Publishing.
4. OECD (2023). Tax Transparency in the Digital Age. Paris: OECD.
5. Kurbanov, F. (2020). Legal Challenges of International Tax Cooperation. Tashkent: Legal Reform Journal.
6. Ruzmetova, N. (2022). Transparency and Taxation of Foreign Entities in Uzbekistan. Tashkent Economic Review.
7. Uzbekistan Tax Code (current edition), Article 215–220.
