International aspects of taxation of manufacturing organizations

The subject of the research is the set of issues and features of international taxation of manufacturing organizations in the context of a globalized economy. The object of the research is transnational corporations, whose activities are related to the movement of capital, tax optimization, and the use of international agreements. The author examines in detail such aspects of the topic as the use of offshore jurisdictions, transfer pricing practices, and the application of special tax regimes in various countries. Particular attention is paid to the analysis of the state policies of leading world economies – China, the United States, and Japan – which apply tax incentives to stimulate high-tech production and attract investment. The study also highlights the role of double taxation treaties and international initiatives aimed at increasing the transparency of the tax environment. A special focus is placed on the interaction between tax policy and the development strategies of manufacturing organizations, as well as the assessment of risks and consequences of aggressive tax planning for national budgets and international competition. The methodological basis includes comparative analysis of tax systems, case studies on transnational corporations, as well as legal and regulatory analysis of international agreements and initiatives (BEPS, Pillar 2). The scientific novelty of the study lies in a comprehensive approach to assessing the impact of international tax instruments on the activities of manufacturing organizations and the formation of global tax policy. The research substantiates that the use of transfer pricing mechanisms and offshore schemes by TNCs not only reduces tax revenues of individual states but also creates new challenges for global tax fairness. It is concluded that BEPS reform measures and the introduction of the global minimum tax under Pillar 2 establish conditions for limiting aggressive tax optimization while encouraging manufacturing organizations towards greater tax transparency and leveling competitive conditions. The study emphasizes that the future development of international tax regulation will be determined by the balance of interests between national states and the global economy, which requires manufacturing organizations to strategically adapt and seek optimal forms of interaction with tax systems.