ENHANCING TAX TRANSPARENCY AND COMPLIANCE IN CROSS-BORDER OWNERSHIP: ANALYTICAL PERSPECTIVES ON CFC DISCLOSURE MECHANISMS
Keywords:
Controlled Foreign Company (CFC), tax transparency, beneficial ownership, international tax compliance, automatic exchange of information (AEOI), OECD BEPS, fiscal reporting, offshore structure, Uzbekistan tax reforms.Abstract
This article explores the growing importance of CFC (Controlled Foreign Company) disclosure mechanisms as tools for ensuring tax transparency and fiscal discipline in the context of cross-border economic activity. The paper analyzes how modern tax systems utilize mandatory reporting standards, beneficial ownership declarations, and automatic information exchange to prevent the erosion of the national tax base. Drawing on OECD guidelines and global practices, the article assesses Uzbekistan’s progress in aligning its tax reporting framework with international CFC compliance standards. Recommendations are provided for introducing a mandatory CFC disclosure form, integrating digital monitoring tools, and enhancing taxpayer awareness of offshore financial interests.References
Musgrave R.A. (1989). Public Finance in Theory and Practice. New York: McGraw-Hill.
Stiglitz J.E. (2000). Economics of the Public Sector. New York: W.W. Norton & Co.
OECD (2015). Action 3 Final Report – Designing Effective Controlled Foreign Company Rules. Paris: OECD Publishing.
OECD (2022). Tax Transparency and Exchange of Information. Paris: OECD.
Internal Revenue Service (IRS). (2023). Controlled Foreign Corporations (CFCs): Overview and Disclosure. Washington, D.C.
Ahmedov Sh. (2021). Tax Policy Reform in Uzbekistan: Challenges and Perspectives. Tashkent: Iqtisod Publishing.
Kurbanov F. (2020). Legal Aspects of International Tax Cooperation. Tashkent: Legal Literature Press.
Uzbekistan Tax Code (Current Edition). Article 215–220. Accessed via Lex.uz.
