РОЗВИТОК ТРАНСФЕРТНОГО ЦІНОУТВОРЕННЯ В УМОВАХ ГЛОБАЛІЗАЦІЇ ТА ШЛЯХИ ПІДВИЩЕННЯ ЕФЕКТИВНОСТІ РЕЖИМУ ТРАНСФЕРТНИХ ЦІН

Abstract

The mechanism of enterprises pricing for moving the main share of profits abroad to low-tax havens has been investigated. The analysis of the existing conflict of interest between MNEs is carried out, they seek to obtain super-profits and the fiscal authorities, must ensure proper control over taxation by introducing the arm's length principle. The article shows the complexity and versatility of the rules of tax control over transfer pricing. The influence of the main factors on the current methods of taxation of enterprises is determined. The nature of transfer pricing risks is characterized and the main tasks of the tax authorities are identified, which is to maximize results, while ensuring business confidence in the tax system. It is shown that transfer pricing schemes are carried out using various techniques of aggressive tax planning, requiring the introduction of additional countermeasures. In the study of transfer pricing in the context of globalization and transnationalization of international relations, it was found that due to the processes of globalization, intersectoral pricing has become a daily necessity for the vast majority of enterprises. The transfer pricing mechanism is the basis of the latest approaches to pricing in the global economy, thereby distorting the level of world fair prices. In modern conditions of development and complication of market relations, there are rapid processes of strengthening foreign economic relations of domestic economic entities and the total manifestation of globalization processes. Due to the fact that globalization is gaining momentum, it is becoming increasingly difficult to maintain the current methods of taxation of TNCs operating in different tax jurisdictions. Transfer pricing is one of the most important aspects of tax minimization in multinational companies. At the same time, the financial interests of the state are expressed in the amount of tax revenues, the solution of this contradiction makes it necessary to improve the tax regulation of transfer pricing between interdependent persons. The practical significance of the research results obtained lies in the possibility of their use in the formation of an appropriate legislative and regulatory framework.