THE CURRENT STATE OF TAX CONTROL OVER TRANSFER PRICING IN UKRAINE

Abstract

The purpose of the article is to summarize and present the genesis of transfer pricing in Ukraine, to identify the problems and to assess the prospects of Ukraine in this direction. Methodology. The theoretical basis was the developments devoted to transfer pricing and the impact of globalization processes on the transfer pricing mechanism of transnational corporations and the system of international regulation. The methodology of the study consisted of general scientific and special scientific methods of research: analysis and synthesis, induction and deduction, methods of analogy, differentiation, generalization. The information base of the study consists of regulatory legal documents, materials of monographic studies of foreign and domestic scientists, textbooks and manuals, international and Ukrainian scientific conferences, articles in periodicals and information base of the Internet. The results of the study showed that transfer pricing as a tax institute appeared in Ukraine in September 2013 against the background of increased attention to transnational corporations and international trade. Unlike many other requirements of tax legislation, transfer pricing has no clear regulatory framework, which creates many problems for both taxpayers and controlling authorities. Ukraine's experience shows that transfer pricing rules focus on shifting the tax base between countries and redistributing profits between related companies, as well as transferring income to low-tax countries. Practical implications. The practical significance of the study lies in a comprehensive analysis and assessment of the current situation of transfer pricing processes taking place in Ukraine. The experience of European countries and judicial practice which formed a number of important and progressive legal positions and conclusions on improvement of transfer pricing control can be used in practice for Ukraine. The practical novelty of the results consists in a comprehensive analysis of the impact of transfer pricing on the current state of tax management as a whole. Value/originality. With proper control over transfer pricing instruments, it is possible to significantly prevent the erosion of the tax base and, consequently, to increase the volume of taxation and ensure the economic security of the state at the proper level.