CURRENT STATE OF TRANSFER PRICING AS AN INSTRUMENT FOR TAXATION OF ENTERPRISES IN UKRAINE

Abstract

Purpose. The aim of the article is the analysis of the current state of transfer pricing in Ukraine. Methodology of research. The following methods are used in the process of research: systemic and dialectical (for the study of the regulatory and legal framework for transfer pricing issues); comparison and synthesis (when developing recommendations on the use of transfer pricing methods). The information base of the study is legislative and regulatory acts of the Verkhovna Rada of Ukraine, the Cabinet of Ministers of Ukraine, normative and legal acts on taxation and fiscal regulation of the State fiscal service of Ukraine; publication of international financial and fiscal organizations; scientific publications of domestic scientists on the issue of tax control of transfer pricing. Findings. The necessity of applying transfer pricing as an element of taxation of enterprises in Ukraine is substantiated. The regulatory and legal framework on transfer pricing issues is defined and the main criteria for recognizing operations are controlled. The list of non-residents operations with which the subject of the tax control of transfer pricing is formed; deficiencies of their implementation have been identified. The basic methods of transfer pricing used by enterprises in Ukraine are defined; recommendations on their application are given. Originality. Recommendations on the application of transfer pricing methods are developed, which will allow enterprises to avoid penalties for violating tax laws. Practical value. The results of the research can be implemented at enterprises of Ukraine of all forms of ownership and types of economic activity, which carry out foreign economic operations.