Abstract: The subject of the present research is the estimation of the criteria defining characteristics of the tax residency of companies. The object of the research is the principles for determining tax residency of companies. The author of the article also underlines that tax residency is one of the fundamental concepts in the construction of the tax system and the common methodological platform for building and formalization of relations of subjects of foreign economic activity with different tax jurisdictions. Thus, the legal regulation is aimed at establishing residency subject composition and status of entities. The guidelines for determining tax residence companies involve (1) the place of incorporation, (2) the center of management and control, (3) the place of management; and (4) the place of effective management. The article describes the features of the principles determining tax residency. The place of incorporation is included as the last criterion for determining tax residency in case of failure of the preceding tests. Using econometric and statistical methods, in his research Grundel analyzes theoretical developments of the current legislation set forth by tax administrations of foreign countries, particularly the establishment of the basic principles of determining the residency of companies. In terms of the manipulation for multinational companies it is difficult to move all the factors influencing the determination of residency jurisdiction in the country with the low tax burden. The author concludes that it is necessary to use the conflict rules for determining the country of residency for physical entities as in the case with legal entities. The provisions set forth by the OECD Model Tax Convention for legal entities should be transferred to the obligation to determine the residency of physical entities. 

Abstract: The subject of the study is to assess the impact on the choice of the excise taxation of tobacco products system. The object of the study are the factors that influence the choice of the excise tax system. It is proved that the choice of the excise rate depends on characteristics of the goods: a) the production of goods is carried out by several companies that are relatively easier process control and collection of the state tax; b) the demand for this product is relatively inelastic - tobacco users are addicted to this product, and therefore not susceptible to price changes; c) the product is a commodity of prime necessity, and d) negative externality of consumption goods.In this paper, using econometric and statistical methods studied acting tax administrations of foreign countries' legislation with regard to the excise tax, and it is proved that the specific excise duties entail lower tax burden on the brand premium compared to cheaper brands. Since the specific excise duties do not depend on changes in the price, they provide a steady stream of revenue to the state budget. Ad valorem excise taxes provide the same tax burden for brands in all price categories. Proceeds from the ad valorem excise duties depends on the price and can change over time depending on the behavior of consumers and producers. It is proved that the levels of excise taxes and cigarette prices tend to be higher in countries applying specific or mixed taxation system, which relies largely on the specific component. Prices of cigarettes higher in countries that rely more heavily on specific excise duties. Levels of tax and lower prices by using hybrid systems, based largely on the ad valorem excise duty, and even lower in those countries that use pure ad valorem system. Noteworthy that the lowest level of prices is noted in countries which do not levy excise duties. It is also clarified that country, is charged exclusively specific excise duty on cigarettes or relying more heavily on specific components of the mixed system of taxation, have the highest average taxes and cigarette prices, and those who charge only ad valorem excise or rely more on the ad valorem component of the mixed system of taxation. They have the lowest taxes and prices.

Abstract: The subject of the research is the development of key performance indicators of tax consultants. The object of the research is the key performance indicators. It is proved that the key performance indicators of the tax consulting business process  are the measure of the company achieving its strategic goals, with which one can evaluate the activities and improve the performance of tax consultants as well as to develop the best approaches to the professional development of staff. It is clarified that each indicator should: (1) be clearly defined; (2) be achievable; (3) be comparable; (4) contribute to the employee engagement; (5) serve as the basis for the analysis. In this paper, using econometric and statistical methods as well as the program «Mathlab» (application «Fuzzy Logic»), performance indicators of tax consultants were decomposed under the Balanced Scorecard and are analyzing depending on the following categories: (1) finances; (2) markets and customers; (3) business processes; (4) training and development. The evaluation parameter "Finances" was decomposed into the following input parameters:  (1) the level of income; (2) the level of costs; (3) the level of intangible assets (goodwill). The evaluation parameter "Markets and customers" was decomposed into the following input parameters: (1) the level of customer savings (the base value for the customer); (2) the level of image and reputation; (3) quality of service (compliance with the law, the level of efficiency); (4) atttraction of customers; (5) retention of customers. The evaluation parameter "Business Processes" was decomposed into the following input parameters: (1) the level of competence maintenance (knowledge of the legislation, industry knowledge, experience); (2) the level of supporting the interests of taxpayers; (3) the level of effectiveness of the internal quality control; (4) the level of understanding of customer needs, effectiveness of communication with customers; (5) the effectiveness of the internal information exchange; (6) the level of compliance with the requirements of the services market; (7) the level of costs. The evaluation parameter "Training and Development" was decomposed into the the following input parameters: (1) the level of provision of search and recruitment of professional staff; (2) the professional qualifications of staff; (3) quality control and knowledge management; (4) the level of compliance with corporate and personal goals. The evaluation of the linguistic variables for "Finance" indicator has been also conducted. To solve the problem, the authors set the rules of the fuzzy input. The question of the application of fuzzy modeling functions to the selection of key performance indicators has been also discussed. 

Abstract: The subject of the research is conflicts-of-law rules for determining the tax residence of companies. The object of the research are the criteria for determining tax residence of companies. The article also focuses on the fact that tax residence of legal entities is determined independently by each state on the basis of one or more criteria. The author describes three groups of connecting factors for the determination of tax residence: 1) connecting factors caused by the creation of a legal entity; 2) connecting factors due to the internal structure of the company's management and decision-making; 3) The connecting factors caused by the activities of a legal entity. Variability of the first group is associated with the state registration of the legal entity. The second group of connecting factors is related to the structure of the internal management and decision-making of the legal entity. The third criterion is preferred according to the OECD Convention for determining tax residence in the event of a dispute between several states regarding a particular legal entity. In this paper, using econometric and statistical methods the author has studied theoretical and practical development of the current legislation issued by tax administrations of other countries, particularly the establishment of the basic principles for determining the residence of companies, criteria for determining residence depending on groups of connecting factors. The author analyzes the characteristics of criterion evaluations to determine tax residence, namely, place of management, place of central management and control, location of the head office, place of actual decision-making. Regardless of which type of management activity is recognized legally relevant by the state, law enforcers have to deal with three aspects: (1) identification of the meaning of management actions; (2) geographic location of activities; (3) determination of a number of persons engaged in this activity. Also, "control" and "influence" should be defined as two different concepts.