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Уклонение от уплаты НДС в трансграничной торговле («карусельные схемы») в странах ЕС и меры их предупреждения
MTIC VAT Fraud in EU Countries and Measures to Counter Them
УДК 336.22
Соколовская Елена Васильевна
старший научный сотрудник Научно-исследовательского института финансового права, Национальный университет государственной налоговой службы Украины, кандидат экономических наук 08201, Украина, г Ирпень, ул. Карла Маркса, д. 31
Elena V. Sokolovskaya
Research Institute of Fiscal Policy, State Fiscal Service of Ukraine
Karla Marksa Str. 31, Irpin, Ukraine, 08201
Статья рассматривает основные аспекты уклонения от уплаты НДС в трансграничной торговле. Цель. Проанализировать уклонение от уплаты НДС в трансграничной торговле («карусельные схемы») стран Европы и меры, направленные на противодействие мошенническим схемам. Задачи. Провести краткий теоретический анализ использования НДС в международной торговле; исследовать текущие проблемы уклонения от уплаты НДС на границе и основные меры противодействия мошенническим схемам; оценить налоговый разрыв по НДС вследствие использования «карусельных схем» в странах ЕС за 2013-2014 гг. Методология. Сравнительный и графический анализ. Результаты. Среди анализируемых стран наибольшее значение налогового разрыва по НДС наблюдалось в Италии, что можно объяснить inter alia существующей системой ежегодной подачи отчетности по НДС (вместо ежемесячной и ежеквартальной), которая существенно усложняет процесс выявления мошеннических схем. Значительный рост данного показателя был отмечен в Чехии, что послужило главной причиной фундаментальных изменений в налоговом законодательстве страны, касающихся порядка подачи отчетности по НДС.
Выводы. Анализ теоретических основ использования НДС в международной торговле товарами позволил выявить особенности, присущие уклонению от НДС в трансграничной торговле (организованная преступность, отмывание денег и проблемы оценки), а также основные мероприятия, направленные на противодействие такому уклонению. На основании оценки существующих стратегий, направленных на сокращение мошеннических схем с НДС во внешней торговле, были выделены три группы таких мероприятий: экономические, институциональные, процедурные (технические).
Ключевые слова: НДС, уклонение, «карусельные схемы», трансграничная торговля, Европейский союз
The article examines the questions of VAT fraud in cross-border trade.
Purpose. To analyze missing trader intra-community (MTIC) VAC fraud in Europe.
Research tasks. To provide brief theoretical analysis of VAT in international trade; to examine current problems in the cross-border VAT fraud and main strategies to counter them; to estimate the MTIC VAT gap in EU countries in 2013-2014.
Methodology. Comparative and graphical analysis Results. We found that among analyzed countries Italy had the largest MTIC VAT gap. It could be explained inter alia by the existing annual VAT returns (instead monthly and quarterly returns), which substantially complicates the process of quick detection of MTIC fraud. The significant increase of ratio of MTIC VAT gap to the VAT revenue was observed for the Czech Republic, which served as the main reason for fundamental changes in VAT reporting system in the country. Conclusion. The analysis of the theoretical background of VAT in cross-border trade in goods allowed us to determine both some main features related to the cross-border VAT fraud (organized crime, smuggling, money laundering and estimation problems) and measures to tackle them. We defined, based on the evaluation of current strategies aiming to reduce the possibilities of cross-border VAT fraud, the three main groups of such measures, notably, economic measures, institutional measures and procedural and technical measures. Keywords: VAT, fraud, missing trader intra-community fraud, cross-border trade, European Union
1. Introduction
The VAT currently continues to spread in the countries worldwide taxing transactions in goods and services. This leads in turn to the growing risks of both tax avoidance and tax evasion, and also of double taxation in the absence of appropriate international VAT coordination. Consequently, the administering of VAT becomes more complicated when cross-border transactions occur and more than one jurisdiction could apply its own VAT rules.
The low level of VAT administering, particularly, could cause the VAT frauds in the cross-border trade.
So, the purpose of this paper is to analyze the MTIC fraud in EU countries and both current problems, related to the cross-border VAT fraud and measures to tackle them. To do this we structured paper as follows. Section 2 reviews recent theoretical and empirical research on the VAT frauds in cross-border trade in goods. Section 3 provides brief theoretical analysis of VAT in international trade. Section 4 estimates briefly the MTIC VAT gap in EU Member States. Section 5 examines current problems in the cross-border VAT fraud and main strategies to counter them. Finally, Section 6 concludes.
2. Literature review
Keen and Smith (2007) described the main forms of noncompliance distinctive to a VAT and considered how they can be addressed, and assesses evidence on their extent in high-income countries [1]. Fedeli & Forte (2009) examined VAT frauds at the EU States' borders by mod-
eling some different collusive characters of these frauds in order to explore their effects on the international trade and the domestic market [2].
Mesdom (2011) estimated fair destination-based VAT. He concluded that border adjustments are easier to administer for tangible goods than for services and to achieve fair results, some proxies for services will be necessary [3]. Magnusson (2009) analyzed the VAT fraud in cross-border trade from the point of view of institutional theory, notably, by involving routines and norms. The author explained the VAT fraud by applying three causal variables — motivated offenders, the crime opportunity structure and the absence of effective guardians of law and order, or in other words, effective control structure, where the crime opportunity structure and control activities — as well as norms, values and attitudes affect the motive formation of the individuals in a social psychological process. He concluded that information and endeavors to influence the attitudes and motive formation of the people who are committing the VAT fraud in cross-border trade [4].
Bukhsh and Weigand (2014) discussed VAT frauds scenarios in the cross-border trade and possible prevention approaches [5]. Walpole (2014) analyzed various anti-fraud measures and he concluded that those that encourage VAT compliance and reduce the VAT burden on compliant businesses could be regarded as preferred options [6]. Gradeva (2014) estimated empirically the VAT evasion in cross-border trade in the context of intra-EU trade flows from the EU-15 to seven of the new Eastern European EU member states, notably, the responsiveness of the trade gap to changes in the VAT rate for the time period of 2004-2009 at the six-digit product level. She found that the trade gap is positively correlated with the VAT rate in three of the seven Eastern European countries [7].
3. Theoretical background
According to OECD (2015), the destination vs. origin principle is one of the fundamental issues of trade policy in relation to the international application of the VAT [8].
Under the destination principle, VAT is levied only on the final consumption occurred within the taxing jurisdiction. Under the origin principle, the tax is levied in the various jurisdictions where the value was added. The key economic difference between the two principles is that the destination principle places all firms competing in a given jurisdiction on an even footing whereas the origin principle places consumers in different jurisdictions on an even footing.
Moreover, the application of the destination principle in VAT achieves neutrality in international trade, since exports are not subject to tax with refund of input taxes (that is, "free of VAT" or "zero-rated") and imports are taxed on the same basis and at the same rates as domestic supplies. According to Sokolovska (2016), countries often choose to reduce tax rates or to exempt them from taxation in order to increase the cross-border trade flows, but such policy generally leads to the destructive "race to the bottom" situation [9].
By contrast, under the origin principle each jurisdiction would tax the value created within its own borders and exporting jurisdictions would tax exports on the same basis and at the same rate as domestic supplies, while importing jurisdictions would give a credit against their
own VAT for the hypothetical tax that would have been < paid at the importing jurisdiction's own rate. ^
This would run counter to the core features of a VAT: ° as a consumption tax. And the origin principle could < distort the economic or geographical structure of the ^ value chain and violate neutrality in international trade. ^ For these reasons, there is widespread consensus that ^ the destination principle is preferable to the origin prin- ¿ ciple from both a theoretical and practical standpoint. o This is the international norm and is sanctioned by WTO " rules. i
In some detail, implementation of the destination prin- | ciple with respect to international trade in goods is relatively straightforward in theory and generally effective in practice, due in large part to the existence of border controls or fiscal frontiers. The VAT on imports is generally collected at the same time as customs duties, although in some jurisdictions collection is postponed until declared on the importer's next VAT return. It is mentioned in "International VAT/GST Guidelines" (2015) that allowing deduction of the VAT incurred at importation in the same way as input tax deduction on a domestic supply ensures neutrality and limits distortions in relation to international trade [8]. According to Mesdom (2011), choice between destination and origin principle has a significant impact on the avoidance of double taxation and the equal treatment of imports compared with locally produced goods [3].
There are different approaches to classify the VAT fraud in cross-border trade. According to the International VAT association report (2007), main sources of VAT fraud are the following:
• the black economy;
• insolvencies;
• missing trader fraud (missing trader intra-community, MTIC) — including "carousel" type fraud;
• other types of fraud, notably:
• invalid deductions of input tax — false input tax invoices, or goods obtained for non-business use, and
• non-payment of output tax, including sales at lower than normal values [10].
• Keen & Smith (2013) defined main frauds that can arise under VAT, notably:
• under-reported sales;
• failure to register;
• misclassification of commodities;
• tax collected but not remitted;
• imported goods not brought into tax [1]. According to Bukhsh & Weigand (2014), VAT frauds
can be divided into the following categories.
1. Acquisition fraud, which is the simplest missing trader fraud where a fraudster imports some goods, assuming that these are zero-rated in the country of origin, and VAT is due in the country where they have been imported. Then the fraudster charges basic price and VAT and later fraudster become missing trader and does not pay VAT.
2. Carousel fraud, which is another version of VAT fraud where missing trader purchases goods from a supplier located in another EU state. Then he sells the goods to a business and charges VAT and later the missing trader disappears without paying the VAT, which in turn starts a chain process where the buying business sells the goods to a second business and charges VAT, paying the excess VAT received from the second business to the budget. The last business in the
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Austria Belgium Czech Republic Denmark Estonia Finland France Germany Hungary Ireland Italy Luxembourg Portugal Slovak Republic Slovenia Spain Sweden UK
P P
P
:
— VAT revenue □ —MTICVATGap
0 20 40 60 80 100 120 140 160 180 200
Billions euro
Fig. 1. VAT revenue and MTIC VAT gap in EU countries in 2013
Source: OECD Revenue Statistics, European Central Bank, Frunza (2016) [11].
chain sells the goods to a broker. After exporting goods in EU, broker reclaims the VAT on next purchase. At this time fraud is revealed that VAT is not being paid by the missing trader.
3. Contra-trading fraud, under which the trader does not claim for reimbursement. The first broker does not submit a claim to obtain a refund of the VAT charged to it. Instead, he imports goods from another EU state, without paying VAT. This VAT charge and import goods chain continues until one broker or another participant of the supply chain submits a claim for a refund of input tax [5].
4. Empirical analysis
Let's analyze briefly the situation with missing trader intra-community fraud in some EU countries in 20132014. For that we used data provided by OECD and European Central Bank concerning the VAT revenue in countries and data of MTIC VAT gap, estimated by Frunza (2016) [11]. The choice of the sample is determined by the available data.
Fig. 1-2 present the dynamics of mentioned parameters in 18 European countries.
It could be easily observed that the biggest economies (Germany, France and UK) have large amounts of VAT revenue and relatively large MTIC VAT gap. Italy is an interesting exception with large volumes of MTIC fraud and relatively small amounts of VAT revenue. According to IMF (2016) [12], there is widespread VAT fraud and evasion in Italian economy, country's VAT compliance gap was estimated to be among the highest in the EU (31%) in 2013. One of the main reasons of that is an existing annual VAT returns (instead monthly and quarterly returns), which essentially delays the detection of MTIC fraud. But according to the ECA Report (2015) [13] based on the results of customs auditing in Germany, Hungary, Italy, Latvia and the United Kingdom, only Italy has automatic checking of VAT numbers in the customs electronic clearance systems, which allow to increase possibility of detection of fraud transactions.
But in order to provide. It should be estimated the ratio of MTIC VAT gap to VAT revenue (table 1).
In 2013 the largest ratios were in Italy, Slovak Republic, Hungary and Spain, while the smallest were in Finland, Sweden and Luxembourg. In 2014 Hungary had the largest ratio, followed by Italy, Czech Republic and Slovak
Austria Belgium Czech Republic Denmark Estonia Finland France Germany Hungary Ireland Italy Luxembourg Portugal Slovak Republic Slovenia Spain Sweden UK
P
P
■ — VAT revenue □ —MTICVATGap
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20 40 60 80 100 120 140 160 180 200
Billions euro
Fig. 2. VAT revenue and MTIC VAT gap in EU countries in 2014
Source: OECD Revenue Statistics, European Central Bank, Frunza (2016) [11].
Republic. The smallest ratios were in Luxembourg, Slovenia and Finland.
The main reason of such situation is the imperfection of fiscal and customs systems in these new EU members. Also the system of reverse taxation in Hungary, which has been established for the distribution of metal waste, and under which the companies transport metal waste from Hungary to final customers in the Slovak Republic and the Czech Republic, contributes to the MTIC fraud.
According to the EU report (2016) [14], in order to tackle the MTIC VAT fraud the joint investigation team (JIT), which includes Hungarian, Czech and Slovak criminal experts, was established. It is organized by the West-Transdanubian Regional Criminal Affairs Directorate of the Hungarian National Tax and Customs Administration and is coordinated by Eurojust and operates under the supervision of the prosecution services of these countries.
The most significant changes of this ratio were in the Czech Republic (twice) and in Hungary. And in order to counter MTIC fraud at the end of 2014 the Czech Republic announced the introduction from 1 January 2016 the new regular "control messages", which include information on any transactions undertaken and the coun-
terparty involved. Such reports should be filled monthly by the VAT-registered persons to enable tax authorities to monitor their VAT affairs more effectively.
The next Section analyzes the measures to counter MTIC fraud in EU countries in more detail.
5. Current problems related to VAT fraud and measures to counter them
The reports of the European Court of Auditors, ECA (2016) [13] stated that the current EU system for fighting cross-border VAT fraud is not effective enough and is hampered by a lack of comparable data and indicators. The main problems in this area are the following:
• absence of effective cross-checks between customs and tax data in most of the Member States;
• problems with the accuracy, completeness and timeliness of data despite the VAT information is shared between Member States' tax authorities;
• a lack of cooperation and an overlap of powers between administrative, judicial and law enforcement authorities. There are some main features related to the cross-
border VAT fraud: organized crime, smuggling, money laundering and estimation problems. Let's consider them briefly.
Table 1
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The ratio of MTIC VAT gap to VAT revenue for 2013-2014
Country MTIC VAT gap/VAT revenue, 2013 MTIC VAT gap/VAT revenue, 2013 Changes, +/—
Austria 0,052 0,041 -0,010
Belgium 0,044 0,028 -0,017
Czech Republic 0,121 0,242 0,121
Denmark 0,041 0,043 0,002
Estonia 0,110 0,050 -0,060
Finland 0,010 0,019 0,009
France 0,028 0,038 0,010
Germany 0,071 0,069 -0,002
Hungary 0,176 0,282 0,106
Ireland 0,051 0,047 -0,004
Italy 0,221 0,269 0,048
Luxembourg 0,013 0,010 -0,003
Portugal 0,071 0,106 0,035
Slovak Republic 0,189 0,227 0,038
Slovenia 0,019 0,016 -0,003
Spain 0,145 0,171 0,026
Sweden 0,012 0,027 0,015
UK 0,053 0,038 -0,015
Source: Author calculations. Organized crime
VAT fraud is often linked with organized crime. According to ECA, €40-60 billion of the annual VAT revenue losses of Member States are caused by organized crime groups and that 2 % of those groups are behind 80 % of the VAT fraud.
Money laundering
It is mentioned in the report of FATF (2007) [15], that there are close links between the laundering of VAT carousel fraud and the laundering of funds from other serious organized crime. Due to the nature of the offence and the substantial scale of the profits available, VAT carousel fraud poses a serious risk of being a favored option to invest money from, and invest money in, other crimes, p. 18
• In order to tackle these challenges the following measures should be done:
• providing Suspicious Transaction Reports;
• ensuring cooperation and information sharing, notably, ensuring more cooperation between the financial sector and public authorities to develop, distribute and offer feedback on indicators and profiles;
• sharing of trends and profiles internationally;
• more use of mutual assistance to help identify the money flows.
Smuggling
The Eurojust meeting (2014) [16] highlighted the fact that, in most cases, excise fraud and VAT fraud are linked, and constitute some of the EU's biggest annual losses of revenue from unpaid duties. Consequently, the two main types of challenges were identified:
• legal and prosecutorial challenges: in addition to different EU legislation in tax and customs area, different approaches to tackle VAT fraud, excise fraud schemes are complex and continually evolving;
• practical challenges, notably, weaknesses in control mechanisms which make the origin of goods, the identity of the traders and the location of the proceeds difficult to determine.
Accordingly, they analyzed such solutions as harmonization of excise tariffs and goods subject to excise, further training for investigatory and judicial authorities, the development of specialized control mechanisms and the improved exchange of information between Member States' authorities. And they identified that the use of the judicial support is the best practice to tackle cross-border excise fraud effectively, which include the exchange of information facilitated through coordination meetings, joint action days and the establishment of joint investigation teams.
It is mentioned in the EU Report (2016) [14] that it is difficult to measure the impact of VAT frauds in the cross-border trade, since the compliance VAT gap is not a reliable estimate of intra-Community VAT fraud, because it includes not only both domestic and cross-border VAT fraud, but also other revenue losses, including those due to legal tax avoidance, traders' insolvency and tax administrations' practices of tolerating tax arrears by companies in difficulties. Moreover, the VAT gap is very sensitive to estimates of the grey economy that are included in GDP data. The EU experts consider that the common risk analysis and an effective feedback mechanism would allow the network to further enhance its role as a quick reaction from tax administrations against cross-border VAT frauds. For the cross-border exchange of information there are clear legal frameworks established for both tax and customs competent authorities [17].
The analysis of current strategies aiming to reduce the possibilities of fraud and exclude new important fraud risks allowed us to summarize them in the Fig. 3.
I. Economic measures
1. Maintenance
of tax neutrality
2. Use
of the reverse
charge
mechanism
3. Delaying refunds of VAT
4. Establishment of an appropriate rate structure and registration threshold
5. Providing
a zero rating exports
II. Institutional measures
1. Generating no disproportionate administrative burdens
for traders and the authorities
2. Maintenance
of tax neutrality
3. Cross-border co-operation
4. Chain liability
III. Procedural and technical measures
1. Ensuring the non-discriminatory treatment in a Member state between both national operators and operators established elsewhere
2. Use of indicators, i.e. guidelines that may indicate VAT fraud in order to check them to be saved from fraud, notably, type of goods, speed of transaction, supply chain, payments
3. Extension of verification
4. Disruption of criminal activity
5. Scrutiny of new VAT registration
6. Real-time logging of trades and verification of counter-parties
7. Collection of VAT in real-time
8. Information exchanges and information checking
9. Use of VAT Locator Numbers (VLNs), under which customers cannot deduct input tax if the VAT is mentioned on an invoice without
a valid VLN
10. Use of D-VAT certification, based on the introduction and implementation of certified tax software in order to calculate automatically the correct tax and VAT liabilities for each transaction, to prepare invoices for these taxes, to link each VAT input or output amount to the correct VAT return, and to complete the VAT return procedure accurately
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Fig. 3. Measures to tackle VAT frauds in the cross-border trade
The experts of OECD in their "International VAT/GST Guidelines" (2015) [8] and the EU VAT expert group (2015) [18] have elaborated main guidelines in order to achieve VAT neutrality in the cross-border trade. With respect to the level of taxation, foreign businesses should not be disadvantaged or advantaged compared to domestic businesses in the jurisdiction where the tax may be due or paid.
This means that there should not be any discriminatory application of the rules because foreign businesses should not end up having a tax advantage compared to domestic businesses in terms of their final tax burden. Consequently, the VAT should not distort competition between foreign and domestic businesses.
To ensure foreign businesses do not incur irrecoverable VAT, jurisdictions may choose from a number of approaches, notably, making supplies free of VAT, allowing foreign businesses to obtain a refund through a specific regime, allowing foreign businesses to obtain a refund through local VAT registration, shifting the responsibility to locally registered suppliers/customers, granting purchase exemption certificates, etc.
In the area of administration and compliance, where specific administrative requirements for foreign businesses are deemed necessary, they should not create a disproportionate or inappropriate compliance burden for the businesses. Domestic businesses and foreign businesses are in different situations in relation to the tax administration. The former will generally has a fixed place of business from which the business is operated, local employees, a local bank, local links to the tax authorities and various forms of identification/registration through bodies, while foreign businesses are less likely to have a legal presence, local staff or links within the local community. And this lack of presence and history in a jurisdiction could be regarded as an element of risk for tax administrations, for which appropriate measures may need to be taken to protect against evasion and avoidance.
Concerning the law aspects, according to the VAT expert group legal certainty is important for business
and tax administrations alike particularly in cross-border scenarios in order to determine the correct place of taxation, i. e. to eliminate double taxation or non-taxation, to avoid VAT costs arising due to assessments and penalties, and to ensure the proper functioning of the single market and provide a level playing field.
6. Conclusion
The analysis of the theoretical background of VAT in cross-border trade in goods allowed us to determine both some main features related to the cross-border VAT fraud (organized crime, smuggling, money laundering and estimation problems) and measures to tackle them.
Using comparative and graphical analysis we provide brief estimation of missing trader intra-community (MTIC) VAT gap in EU countries in 2013-2014. We found that among analyzed countries Italy had the largest MTIC VAT gap. It could be explained inter alia by the existing annual VAT returns (instead monthly and quarterly returns), which substantially complicates the process of quick detection of MTIC fraud. The significant increase of ratio of MTIC VAT gap to the VAT revenue was observed for the Czech Republic, which served as the main reason for fundamental changes in VAT reporting system in the country.
We defined, based on the evaluation of current strategies aiming to reduce the possibilities of cross-border VAT fraud, the three main groups of such measures, notably, economic measures, institutional measures and procedural and technical measures.
Литература
1. Keen M., Smith S. VAT Fraud and Evasion: What Do We Know, and What Can be Done? Fiscal Affairs Department // IMF Working Paper, 2007. 35 р.
2. Fedeli S., Forte F. Models of Cross-Border VAT Fraud. Dipartimento di Economia Pubblica // Working Paper N 123. Roma, Giugno, 2009. 25 p.
3. Mesdom B. VAT and Cross-Border Trade: Do Border Adjustments Make VAT a Fair Tax? Tax Analysts. 2011. Р. 192-203.
< 4. Magnusson D. Investigating VAT fraud in connection with ш cross-border trade within the European Union. Jonkoping о International Business School: [Электронный ресурс]. Рек жим доступа: http://www.gma-bg.org/upl_doc/no%2009% ^ 20magnussson%20sofia%20ny%20eng%20ver.pdf.
5. Bukhsh F., Weigand H. VAT Fraud: Possible technical and ontological solutions. Tilburg University: [Электронный ре-cl сурс]. Режим доступа: http://vmbo2015.blogs.dsv.su.se/ ^ files/2015/02/VMB02015_submission_14.pdf. 2 6. Walpole M. Tackling VAT Fraud // International VAT Monitor. о Sept./Oct. 2014. Р. 258-263.
□c 7. Gradeva K. VAT Fraud in Intra-EU Trade. Goethe University. ^ Frankfurt, 2014. 33 p.
s 8. International VAT/GST Guidelines. OECD, 2015. 81 p.
9. Sokolovska O. Race to the bottom in international tax competition: some conceptual issues // Journal of Tax Reform. 2016. Vol. 2, N. 2. Р. 98-110: [Электронный ресурс]. Режим доступа: http://jtr.urfu.ru/fileadmin/user_upload/site_ 40_4525/Sokolovska.pdf.
10. Combating VAT fraud in the EU the way forward. International VAT association. European Commission, 2007. 49 p.
11. Frunza M. Cost of the MTIC VAT Fraud for European Union Members (April 4, 2016). Available at SSRN: http://ssrn. com/abstract=2758566.
12. Italy: Technical Assistance Report-Enhancing Governance and Effectiveness of the Fiscal Agencies. IMF Country Report. № 16/241, 2016. 69 p.
13. Fighting VAT fraud: "time to step up efforts". ECA Press, 2016: [Электронный ресурс]. Режим доступа: http://www.eca. europa.eu/Lists/News/NEWS1603_03/INSR_VAT_FRAUD_EN. pdf.
14. Tackling intra-Community VAT fraud: More action needed. European Court of Auditors Special Report, 2016. N 24. 58 p.
15. Laundering the proceeds of VAT carousel fraud. FATF & OECD, 2007. 33 p.
16. EUROJUST News. Issue 11. March 2014. 20 p.
References
1. Keen M., Smith S. VAT fraud and evasion: What do we know, and what can be done? IMF Working Paper, 2007, no. WP/07/31. 35 p. Available at: https://www.imf.org/ex-ternal/pubs/ft/wp/2007/wp0731.pdf.
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7. Gradeva K. VAT fraud in intra-EU trade. Goethe University Frankfurt, 2014. 33 p.
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9. Sokolovska O. Race to the bottom in international tax competition: Some conceptual issues. Journal of Tax Reform, 2016, vol. 2, no. 2, pp. 98-110. Available at: http://jtr.urfu. ru/fileadmin/user_upload/site_40_4525/Sokolovska.pdf
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14. Tackling intra-community VAT fraud: More action needed. European Court of Auditors Special Report, 2015, no. 24. 58 p. Available at: http://www.eca.europa.eu/en/Pages/ DocItem.aspx?did=35308.
15. Laundering the proceeds of VAT carousel fraud. Paris, FATF/OECD, 2007. 33 p. Available at: http://www.fatf-gafi. org/media/fatf/documents/reports/Laundering%20the%20 Proceeds%20of%20VAT%20Caroussel%20Fraud.pdf.
16. EUROJUST News, March 2014, no. 11. 20 p.
