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A.Pulatov,
Senior Lecturer
Head of Legal Studies Department
Westminster International University in Tashkent
TAX AVOIDANCE ISSUES IN DIGITAL ECONOMY.
Annotation:
current regulation frameworks made it dif-
ficult to impose tax on digital economy. A digital economic
tax issue varies depending whether it is a corporate in-
come tax or consumption tax. In my research I will ad-
dress taxation issues in digital economy and what meth-
ods companies using to avoid taxations.
Keywords:
digital economy, Multinational Enterprise
(MNE), transfer pricing.
Аннотация
:
нынешние
рамки
регулирования
еще
затруднили
введение
налога
на
цифровую
экономику
.
Проблема
налогообложения
цифровой
экономической
деятельности
варьируется
в
зависимости
от
того
,
яв
-
ляется
ли
это
корпоративный
подоходный
налог
или
налог
на
потребление
.
В
данной
научной
работе
будут
рассмотрены
вопросы
налогообложения
в
цифровой
экономике
и
методы
,
используемые
компаниями
для
избежания
налогообложения
.
Ключевые
слова
:
цифровая
экономика
,
трансна
-
циональная
компания
,
трансфертное
ценообразова
-
ние
,
вывод
доходов
/
прибыли
из
-
под
налогообложения
Аннотация
:
амалдаги
солиқни
тартибга
солувчи
меъёррлар
ҳозирги
рақамли
иқтисодиётни
тартибга
солишда
муайян
қийинчиликларга
дуч
келмоқда
.
Рақамли
иқтисодиётда
солиқ
масаласи
корпоратив
даромад
солиғи
ёки
истеъмол
солиғи
ҳисобига
боғлиқ
.
Ушбу
тадқиқотда
рақамли
иқтисодиётни
солиққа
тортиш
масалалари
ва
солиқ
тўлашдан
бўйин
товлаш
учун
қандай
усуллар
қўлланилаётгани
қўриб
чиқилган
.
Калит
сўзлар
:
рақамли
иқтисод
,
трансмиллий
компания
,
трансферт
баҳо
белгилаш
,
даромад
ва
фойданинг
солиққа
солинишидан
бўйин
товлаш
.
Introduction to Digital Economy
Oxford dictionary defines
digital economy
as “An
economy which functions primarily by means of digital
technology, especially electronic transactions made using
the Internet” [1].
For the first time term 'Digital Economy' started emerg-
ing in early 90’s and coined by Don Tapscott in his
book “The Digital Economy: Promise and Peril in the Age
of Networked Intelligence”, in his book he was one of the
first who predicted that internet will massively change they
way we do the business [2].
OECD in his “Addressing the Tax Challenges of the
Digital Economy” report states “The digital economy is the
result of a
transformative process
brought by information
and communication technology (ICT), which has made
technologies cheaper, more powerful, and widely stand-
ardised, improving business processes and bolstering
innovation across all sectors of the economy” [3].
Although one can not clearly define the boundaries of
the digital economy, the transactions in the digital econo-
my can be categorised as follows: ‘electronic services,
supply over the Internet of services other than electronic
services and supply of goods ordered online [4].’ The digi-
tal economy is driven by ‘content production, consumption
and indexation’ [5]. The
monetisation of personal data
plays a key role in the digital sector. At the same time, it is
a challenge to calculate the
value creation
in the digital
sector as consumers receive services free of charge in
exchange for providing data. The use of big data is anoth-
er key characteristic of the digital sector, which is now
incorporated in every level of international economy. It is a
pool of data collected, diffused, aggregated, stored and
analysed, which creates value by increasing transparency,
improving performance management and decision-
making, and by developing tailored products or services or
even
new business models
. Digital businesses can be
easily contestable ‘as market power can be challenged by
entrants more easily and often faster than in more tradi-
tional fields of the economy.’ The digital sector is more
dependent on intellectual property than traditional brick-
and- mortar business [6].
Digital economy is growing every day, and becoming
economy itself.
1.1 Electronic Commerce
Electronic Commerce is commonly known as all kinds
of business conducted online by using internet [7]. The
definition provided by the OECD is “An electronic transac-
tion is the sale or purchase of goods or services, whether
between businesses, households, individuals, govern-
ments, and other public or private organizations, conduct-
ed over computer-mediated networks. The goods and
services are ordered over those networks, but the pay-
ment and the ultimate delivery of the good or service may
be conducted on or off-line” [8].
E-commerce can be categorized into four main catego-
ries: Business to Business (B2B), Business to Consumer
(B2C), Business to Government (B2G), and Consumer to
Consumer (C2C). Among these four categories, the politi-
cal debate mostly focused on the B2B and B2C type of
activities. Most Multinational enterprises use the internet to
get access to the rest of the world in a same way as small
and medium size of enterprise.
As E-commerce is a very new type of business con-
ducted over the internet which changes the traditional way
of conducting business, it is important to review the cur-
rent tax rule whether or not it is possible to apply to in-
come generated in the new way both theoretically and
administratively. With the purpose to evaluate the existing
tax rules conceivably and carefully, it is significant to un-
derstand how the technology makes E-commerce operate.
It is believed that without the accurate understanding of
how those incomes generated, it’s impossible for the tax
authorities to make a new international taxing system ef-
fectively implemented.
1. Why taxation of MNEs in digital economy is im-
portant?
While corporations thinking of their own financial bene-
fit create different tax avoidance schemes and save them-
selves millions, the population suffering from austerity
measures during the crisis times makes one argue that tax
avoidance is an evil and dishonest activity [9]. When it
comes to countries deterring themselves against tax
avoidance, they should preserve the balance between
over deterrence in order not to frighten the investors and
under deterrence in order not to create loopholes in tax
regulation and suffer economic loss.
In the EU all Member States have different taxation
schemes. Countries with more requirements for social
infrastructure have higher taxes than tax-haven countries
like Luxembourg for which it is more beneficial to have a
low tax base and create more incentives for investors to
move their businesses there. This difference in approach-
es creates a great challenge especially taking into consid-
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eration that they have to comply with Article 150 of TFEU
as well, and not to create tax obstacles and hinder the
functioning of the Single Market.
The global trend in taxation is that the average tax rate
is falling and it is now around 23% and used to be 40%.
For example, the UK’s tax rate has decreased from 30%
to 22.6% in the recent years. There is an impression of
unfairness, because MNE’s that already earn billions pay
even less tax than they used to couple of decades ago
[10].
However, the MNEs “conscience” is not troubled by
their ruthless tax planning activities since they stipulate
that decreased share of tax in the GDP is related to the
crisis in the euro area and not to the development of e-
commerce and the rise of corporate income tax base. In-
stead, they allege that it is not for the digital economy
budgets are suffering loss of taxable income, but it is a
natural outcome of free capital movement and account
liberalization, which in its turn led to profit shifting, transfer
pricing and hybrid mismatches and creation of tax havens
and it existed before the Internet [11].
Diversity in governments’ fiscal policies around the
world is seen by some as a “
healthy” tax competition
by
MNEs and they see tax harmonization as the only solution
to this. It is reasonable that MNEs use these mismatches
to maximize their post-tax profit in order to meet their in-
vestors’ expectations [12].
Another argument of MNEs in favor of irrelevance of e-
commerce to the decreased tax shares in GDP is that
effective tax rates (income tax paid based on the pre-tax
earnings) paid by US web firms such as Facebook and
Amazon is actually higher than tax amounts paid by Euro-
pean largest MNEs. They further brought Google 19.91%
and eBay’s 16.32% effective tax rates and compared them
to European industrial leaders like Volskwagen and Re-
nault [13].
There is even more progressive proposal of rejecting
corporate tax at all and replacing it with a revenue based
tax and suggest corporate sales taxing. However, organi-
zations like Tax Justice Network argue that corporate tax
restraints political and economic imbalances and criminal
behavior and at the same time it promotes financial trans-
parency and democracy, boosts economic growth and
increases profits crucial for public services [14].
One needs to find a balance between these two oppo-
sites in order to provide fulfillment of public interests with-
out losing public revenues.
Recently, Lux Leaks has disclosed some private ar-
rangements between Luxembourg and more than 300
MNEs, where the state of Luxembourg had cut their taxes
to a very large amount and they had not been required
even a minimum physical presence in the country. The
conditions of state aid and exceptions to them are listed in
Article 107 of TFEU. In order to check the legality of this
and other similar state aids in Luxembourg, Ireland, Bel-
gium and the Netherlands, the EC started investigations
[15].
Tax avoidance and planning may create disadvanta-
geous conditions to compete in the market for companies,
which do not have an opportunity to do a similar planning
due to their business model, size or geographic focus [16].
A study conducted by the European Commission re-
vealed that MNEs profit from tax rates that are 3.5% lower
than for domestic companies and small/medium enterpris-
es are seriously disadvantaged as they pay higher rates
[17].
Tax planning and avoidance has the capacity to distort
competition by using existing escape clauses in various
tax systems and transferring profits to zero tax or low-tax
jurisdictions where no economic activity is conducted.
Since harmful tax competition results into a race to the
bottom, the tax base is eroded and profits are shifted.
While winners are mobile factors, losers are factors of
production, such as labor, and fewer companies with lim-
ited mobility [18].
Digital monopolies curb competition and innovation,
creating the risk of monopolizing other markets and the
incentive to lock-in customers. In addition, the positions of
the gatekeepers of the Internet providers can negatively
affect the dynamics of the market. State aid in deploying
broadband access can disrupt markets [19].
For instance, when geo-blocking causes harm to the
Digital Single Market, Articles 101 and 102 of the TFEU
can be used to remove the constraints imposed by domi-
nant companies [20].
Abuse of dominant position (Article 102 of the TFEU)
occurs in the form of either exclusive (foreclosure) or ex-
ploitative. In the first one - restrictions of gatekeeper ac-
cess or use of the market (favouring own services, exploi-
tation of third party content and data to the detriment of
competitors and impeding supplier changes by customers)
can amount into an abuse. In the second case, the use of
third-party content or data or restricting customers from
switching providers are examples of abuse [21].
In addition to the investigations by the European
Commission against big tech companies in February
2015, the European Commission initiated an investigation
on the Belgian excess profit tax scheme for allegedly dis-
torting competition by allowing companies to lower their
taxes by 50 to 90% from excess profits resulting from a
subsidiary of a multinational group. Hence, the Commis-
sion concluded that the tax regime was illegal and asked
for a
€
700 million recovery of unpaid taxes from 35 MNEs
[22].
3. Analyzing taxation of issues of digital economy
3.1.
Common tax avoidance practices by MNE in
digital economy.
3.1.1. Avoiding presence in market country or
Nexus.
Extremely mobile intangibles with complex business
models make the digital sector hard to pin down for na-
tional tax systems and intangibles “may lie at the heart of
any effective recalibration of how international taxation
rules and guidance respond to changing patterns and
characteristics of multinational and global businesses”
[23].
Under the current international tax rules, remote sales
by an e-tailor are not taxable and the presence of capital
(such as a stand-alone server) is sufficient to establish tax
jurisdiction. This situation may be even more complicated
in future by the widespread use of 3D printers at home
and workplaces [24].
Thus, the concept of PE which has been used over the
centuries is inapplicable for digital businesses such as a
web store as it does not require a physical presence. Digi-
tal economy allows businesses to supply markets and to
accrue virtual profits without any need for legal or physical
presence at the local level [25].
This “dematerialization” [26] or sometimes refered also
as “cyberisation” of the tax base happens when the busi-
ness is conducted through a website without physical
presence or when “replacing conventional sales outlets in
the market country with online licensing of software or
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specifications if the products can be produced through 3D
printing” [27].
3.2.2. Artificial Contractual Arrangements to Avoid
PE
Many businesses in the digital economy use some
form of physical presence to reach customers, deliver
goods, or provide support. As identified by the OECD
BEPS Action Plan, the supplier may adopt measures or
structures to “artificially” avoid having a permanent estab-
lishment in the market country. Examples include the use
of limited function distributors or “commissionaire ar-
rangements”, the use of toll-manufacturing or contract
manufacturing contracts to avoid having a PE or full-
fledged manufacturing subsidiary, and “artificial” fragmen-
tation of activities to avoid the temporal requirement of a
PE or to qualify for the exceptions to PE status for prepar-
atory and ancillary activities under Article 5(4) of the
OECD Model [28].
For instance, the use of a fixed place of business to
purchase, warehouse and deliver merchandise may be an
activity of preparatory or auxiliary
nature for traditional
businesses while constituting a substantial or core activity
for e-commerce. Similarly, online or Internet sale of digital
goods and digital services is a core business of an enter-
prise requiring no physical stores, agencies or assets but
could be defined as preparatory or ancillary activity ac-
cording to these exceptions. Finally, it is difficult to talk
about residence when it comes to cloud computing [29].
The exceptions under Article 5(4) of the OECD Model
Tax Convention [30] can give rise to the following practic-
es of MNEs to avoid PE status. Moreover, tax residence or
physical location is disregarded by the customer and does
not influence his/her choices.
−
Migrating services that can be provided in person
to cyberspace and keep in-person
services at a minimum which gives no rise to PE;
−
Converting royalties into services fees and avoid
withholding tax by transforming technical services or pro-
vision of software etc. into services delivered online; and
−
Monetizing location relevant data created by local
customers without any compensation [31].
3.2.3 Avoiding Withholding Tax
A non-resident company can be asked to pay taxes in
a country, where it generates income
via payments such as interest or royalties. This type of
taxation is called
withholding tax
and intends to tackle
characterisation issues by imposing a tax on certain pay-
ments made by residents of a country for digital goods or
services provided by a foreign provider. One practical
challenges of withholding in the case of transactions with
individual consumers. One option to deal with the practical
challenge would be “to require withholding by the financial
institutions involved with credit card payments or electron-
ic payments” [32].
MNEs often use tax havens or favorable tax regulation
countries to avoid withholding tax using treaty shopping
and creating shell companies in low tax jurisdictions. For
example, Amazon saved billions by paying almost zero tax
from profit using sophisticated tax saving models [33].
Sometime it is referred as double non-taxation, which al-
lows for the non-payment of withholding taxes in the
source country and in the intermediary countries. Using
complicated tax saving system the final tax collection oc-
curs in a tax haven.
Another point is effect of tax treaties in developing
countries, and their tax rights in tax treaties including limi-
tations to withholding taxes. Article in action aid stated
“Uganda signed a tax treaty with the Netherlands that
completely takes away Uganda’s right to tax certain earn-
ings paid to owners of Ugandan corporations, if the own-
ers are resident in the Netherlands. A decade later, as
much as half of Uganda’s foreign investment is owned
from the Netherlands, at least on paper. The result of the
current treaty is lost tax revenue in Uganda, which could
have paid for essential public services for the Ugandan
people” [34].
Commonly used methods by companies to eliminate or
reduce tax in the country of residence or in the intermedi-
ate country may include preferential tax regimes, the use
of hybrid mismatch arrangements or excessive deductible
payments[35].
3.2. Mostly used BEPS methods by MNEs in digi-
tal economy
−
Artificial internal trading of intangibles
:
Through simulation internal trading of intangibles they shift
profit, for instance, management fees or international
property licensing.
−
Thin capitalisation
: A company may reduce risk
at local company level by limiting capitalisation. A local
subsidiary of a business selling online products may have
a warehouse with limited earnings.
−
Internal debt shifting
: In cases where a subsidi-
ary is heavily indebted to another one, the high interest
rates decrease the tax base of one subsidiary while in-
creasing the profits of the other.
−
Transfer pricing
: A company may sell goods
and merchandise between subsidiaries at a very high
price to make some subsidiaries richer or poorer artificial-
ly. It may sell services (i.e. management or consultancy) to
its subsidiaries, which may be even imaginary services.
−
Artificial contractual arrangements
: Functions
may be carried out by local contractual staff not having
authority to conclude contracts on behalf of a non-resident
enterprise.
−
Circumvention of Controlled Foreign Compa-
ny (CFC) rules
: Complex hybrid arrangements (double
non-taxation, double deduction, long-term deferral) may
be designed to benefit from different tax systems and their
dealings with financial instruments, asset transfers or enti-
ties with the aim of circumventing CFC rules.
3.2.1. Intellectual Property (IP) Box
Preferential tax regimes: In case of MNEs, usually,
when they do tax planning, location of their subsidiaries
plays important role. Usually, they locate subsidiary which
own brand, copyright, and patents to low tax jurisdictions,
and liking other subsidiaries with them to pay royalties.
One of the methods is a
patent box
. A patent box or
sometime also know as Intellectual Property (IP) Box is a
“tax advantage offered to companies for income earned
from intellectual property. IP box tax rates are in general
applied to IP profits and they allocate IP expenses (man-
agement expenses or financing costs) to IP income” [36].
However, numerous MNEs abusing IP box to reduce
their tax base and to shift profits to patents in low tax juris-
dictions. According to European Commission report of
2015, patent box became BEPS tool as well, and does not
aim innovation and research [37].
Tax authorities increasingly struggle to tax income
from intangible assets in a way that prevents IP income
from being shifted abroad. Moreover, policy makers are
concerned that “research and development (R&D) as well
as innovative activities, which are associated with positive
spillovers, are relocated to other countries for tax reasons”
[38]. The intellectual property such as patents, trademarks
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and copyrights constitute a challenge as they lack a fixed
location (absence of nexus) and therefore can be easily
relocated at nontax costs.
The UK is encouraging returns on earnings from pa-
tents and other innovations and reduces the tax rate to 10
% [39] and this also creates concern forEU member states
if this leads to race to bottom. Moreover, US announced
its own patent box as well [40].
In 2014, IP box regime reached 12 in Europe. Regimes
differ considerably in terms of the “IP Box tax rate, the
scope of eligible types of IP and IP income, the treatment
of acquired IP and the calculation of the IP Box tax base”
[41]. Malta had lowest rate which is 0% and highest was
France 15 %, widest range of eligible types of IP can be
found in Switzerland, Cyprus, Hungary, Liechtenstein and
Luxembourg, which apply to designs, models, trademarks,
copyrights (software etc.) and other types of intangibles in
addition to patents. European Parliament study concluded
that most of the IP regimes were more concentrated on
attracting IP income rather than innovation and R&D.
Some of them were so controversial, that violated EU
competition law. For instance, Cyprus IP box regime was
so wide in range, that it even included non-IP ranges [42].
3.2.2. Sweetheart deals
Tax rulings
or preliminarily also referred to as ‘sweet-
heart deals’ include information by financial authorities that
is legally binding and these rulings regularly give rise to
criticism in connection with tax dumping. Although, “ at the
first sight this sounds harmless and fundamentally is also
sensible in order to create legal certainty as it is possible
to clarify in advance how particular complex tax situations
are to be dealt with before they actually arise” [43].
One type of ruling is the so-called
advanced pricing
agreements
(APAs), which are used by multinational cor-
porations to get approval of their transfer pricing methods.
Tax rulings have attracted increasing amounts of attention
since they have been known to be used by multinational
corporations to obtain legal certainty for tax avoidance
practices. The documents exposed in the LuxLeaks scan-
dal were APAs [44].
Even after the LuxLeaks scandal, the number of
“sweetheart deals” and APAs did not decrease. Denmark
modified its APA procedures, which allows to “disregard a
ruling if the value of transferred assets is significantly dif-
ferent from the value approved in the ruling, justifying this
change by difficulties of pricing intellectual property cor-
rectly” [45].
3.2.3. Transfer Pricing
A transfer price is the price that is set for the exchange
of goods and services between various subsidiaries of a
corporate group. According to the OECD’s arms-length
principle, subsidiaries of a group are treated as “if they
were legally independent companies and their transac-
tions are organized following standard transaction related
methods and profit methods. The original aim of this prin-
ciple was to ensure that all countries could share the prof-
its as if they were made by a legally independent compa-
ny” [46].
Yet, it is criticised for having ‘failed in its declared goal
of creating markets inside multinational corporations
where they do not really exist.’ The OECD acknowledged
in the 1960s that market based prices are often nowhere
to be found, allowing the use of formulary methods for
calculation of the prices that corporations use in intra-firm
trade [47].
MNEs can use transfer pricing to attribute income to
tax havens by arbitrarily inflating prices for goods and ser-
vices. “This is a widespread practice in the digital sector
where intangible assets such as patent rights, royalty
rights or marketing rights can be established in low-tax
jurisdictions or tax havens”. “…subsidiaries based in high-
tax jurisdictions then have to pay royalties for these intan-
gible assets (company names, software licenses etc.),
which can be deducted form their tax base as operating
expenses” [48].
3.2.4. Hybrid Mismatches
Hybrid mismatches are arrangements designed to
benefit from different tax systems and their dealings with
financial instruments, asset transfers or entities with the
aim of double non-taxation. For example, “MNEs take ad-
vantage of differences in tax regulations by using a finan-
cial instrument, which can be regarded as equity (deducti-
ble) in one country but as dividend (tax-exempt) in anoth-
er” [49].
3.3. Major BEPS Risks in the Area of Indirect Tax-
ation
Advances in digital technologies make it possible for
MNEs and other companies to “legitimately” take the tax
base (income tax as well as
VAT
) into cyberspace. The
current rules were not designed for the digital economy.
“Traditional international sales were effectuated with cus-
toms collecting duties and filling forms with costs yet one
cannot view the forms filled by a customs officer in the
case of an online purchase as it is only sent from supplier
to user. Hence, attaching VAT to online sales constitutes a
big challenge, especially because there is no intermediary
involved” [50].E-commerce can be carried out through
emails, websites, distance selling, digital downloads etc.
Whether ecommerce should be taxed has been a matter
open to discussion as more and more transactions are
carried out online [51].
VAT taxing of e-commerce or digital economy is prob-
lematic due to anonymity of parties, difficulty to determine
the amount of tax, lack of trail, tax havens transactions,
companies’ operations located in multiple jurisdictions, tax
authorities lack of capacity to identify companies and to
supervise and manage consumption taxes, additionally,
that kind of operations might be costly [52].
‘The problem of cyberisation affects VAT collection. It
is impossible in Business to Consumer (B2C) transactions
if the foreign online vendor has no physical presence and
does not register for VAT in the market country. In Busi-
ness to Business (B2B) transactions, if the purchased
goods or services qualify for input tax credit to the local
business purchaser, the VAT revenue loss may be insig-
nificant’ [53].
Cross border trade creates new challenges for VAT
systems in the absence of an international framework to
register and manage payments to a large number of tax
authorities whereas managing tax liabilities by a high vol-
ume of low value transactions is administratively difficult
[54].
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ЗАКОНОДАТЕЛЬСТВА
УЗБЕКИСТАНА
2018
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М
.
Уразалиев
и
.
о
.
доцента
кафедры
«
Уголовное
право
и
криминологии
»
ТГЮУ
УЧАСТИЕ
МЕСТНЫХ
ОРГАНОВ
ГОСУДАРСТВЕННОЙ
ВЛАСТИ
НЕКОТОРЫХ
ЗАРУБЕЖНЫХ
СТРАН
В
ОРГАНИЗАЦИИ
ПРАВООХРАНИТЕЛЬНОЙ
ДЕЯТЕЛЬНОСТИ
Аннотация
:
в
статье
автор
раскрывает
роль
мест
-
ных
органов
государственной
власти
в
организации
правоохранительной
деятельности
в
некоторых
зару
-
бежных
странах
,
взаимоотношения
с
различными
пра
-
воохранительными
органами
,
их
права
и
полномочия
в
этой
сфере
.
Ключевые
слова
:
государственная
власть
на
ме
-
стах
,
местный
орган
,
система
местного
самоуправле
-
ния
,
коммуна
,
местный
совет
,
префект
,
координация
,
полномочие
,
правоохранительный
орган
,
территори
-
альное
управление
.
Аннотация
:
мақолада
муаллиф
айрим
хорижий
мамлакатларда
маҳаллий
ҳокимият
органлари
томонидан
жойларда
ҳуқуқни
муҳофаза
қилиш
фаолиятини
ташкил
этиш
борасидаги
роли
,
хусусан
,
турли
ҳуқуқни
муҳофаза
қилувчи
органлар
билан
ўзаро
муносабати
,
бу
борадаги
ҳуқуқ
ва
ваколат
доираси
кўриб
чиқилган
.
Калит
сўзлар
:
маҳаллий
давлат
ҳокимияти
,
маҳаллий
орган
,
маҳаллий
ўзини
ўзи
бошқариш
тизими
,
коммуна
,
маҳаллий
кенгаш
,
префект
,
мувофиқлаштириш
,
ваколат
,
ҳуқуқни
муҳофаза
қилувчи
орган
,
ҳудудий
бошқарув
.
Annotation:
in the article author had shown the role of
the municipal bodies of the state power upon the organiza-
tion of law defense activity in some foreign countries as
well as the relations with different law defense bodies,
their rights and powers in this sphere.
Keywords:
municipal state power, municipal div, the
municipal bodies system, commune, municipal council,
prefect, coordination, power, law defense div, territorial
government.
Формирование
в
Узбекистане
гражданского
обще
-
ства
в
условиях
глобализации
и
стремительно
меня
-
ющегося
современного
мира
повышает
ответствен
-
ность
местных
органов
власти
за
реализацию
задач
социально
-
экономического
развития
страны
,
и
тем
самым
создает
необходимые
предпосылки
для
того
,
чтобы
оптимизировать
действующую
систему
государ
-
ственного
управления
,
в
том
числе
обеспечить
более
эффективное
взаимодействие
органов
государствен
-
ной
власти
на
местах
(
представительных
органов
вла
-
сти
и
органов
исполнительной
власти
на
местах
)
и
территориальных
подразделений
правоохранительных
органов
(
органов
юстиции
,
прокуратуры
,
внутренних
дел
,
службы
государственной
безопасности
,
налого
-
вых
органов
и
др
.)
по
координации
правоохранитель
-
ной
деятельности
в
регионе
.
По
мере
осуществления
в
стране
судебно
-
правовой
и
административной
реформ
,
структуриро
-
вания
правоохранительной
системы
,
специализации
ее
элементов
все
более
очевидной
становится
необ
-
ходимость
развития
теоретических
основ
координации
правоохранительной
деятельности
,
особенно
в
сфере
профилактики
и
предупреждения
преступности
,
по
-
