Issue: № 4, 2025
Doi: https://doi.org/10.37634/efp.2025.4.2
Introduction. Mandatory disclosure of information on cross-border transactions and exchange of information between tax administrations is crucial to ensure that government authorities have the necessary information to effectively perform their duties. The purpose of the paper is to study the legal aspects of mandatory disclosure of information on cross-border transactions of taxpayers and automatic exchange of information between tax administrations, and also to assess the effectiveness of existing mechanisms for disclosure of information on cross-border transactions. Results. The paper analyzes European legislation (DAC6, DAC7), OECD and FATF BEPS standards, identifies regulatory gaps and provides recommendations for improving Ukrainian legislation in this area. The author identifies the main characteristics of financial mechanisms that create reporting obligations to national tax authorities. Mandatory disclosure of cross-border information on cross-border transactions of taxpayers is not only tax control, but a comprehensive mechanism that covers the fight against tax evasion, money laundering and financial fraud. Conclusion. The author concludes that, despite international standards, the most vulnerable to mandatory disclosure are those cross-border transactions that are carried out through decentralized platforms (DeFi), involve intangible assets, have an atypical settlement structure (barter, royalties, intra-group loans) or are conducted through offshore jurisdictions. Adapting Ukrainian legislation to international standards and taking into account European approaches to legal regulation of disclosure of information on cross-border transactions will help reduce the risks of tax evasion, strengthen the institutional capacity of public authorities, and increase confidence in the financial system.
Keywords : tax relations, taxpayers, mandatory disclosure, information on cross-border transactions, automatic exchange of information, tax planning
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