Abstract
The features of transfer pricing in Ukraine have been considered. It has been established that transfer pricing in Ukraine is at the stage of formation. The features and prospects for the implementation of international transfer pricing requirements using the «Three-tier model of transfer pricing documentation recommended by the OECP (step 13 of the BEPS plan)» have been identified. The legal aspects of regulating the prevention and minimization of the movement of profits, tax evasion by transnational corporations, in particular, the BEPS package, and others have been considered. The place of Ukraine in the Paying Taxes rating in 2015-2020 is determined. Trends 2015-2020 testify to the formation of tax discipline regarding the timeliness and completeness of reporting on transfer pricing. The dynamics of the submitted reports on controlled transactions in Ukraine in quantitative and value terms in 2013-2020 has been analyzed. The volume of controlled transactions by country and by subject of transactions in 2020 was investigated. It was found that the largest share in the total volume of controlled transactions is occupied by banking services (37%) and transactions with goods (35%), and the largest volume of controlled transactions is carried out in Switzerland. The features of the implementation in Ukraine of the BEPS plan as an international project of the Organization for Economic Cooperation and Development (OECD) and the G20 countries are considered. The innovations in tax legislation in the field of transfer pricing and the peculiarities of introducing a three-level reporting structure on transfer pricing in Ukraine have been described. The World Transfer Pricing 2022 rating of Ukrainian companies offering transfer pricing services is presented. The problems that hinder the effective implementation of the requirements of international transfer pricing in Ukraine have been identified and measures have been proposed that should be taken to overcome them.
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