Abstract
This study is aimed at development of the theoretical foundations of transfer pricing mechanism implementation at Ukrainian enterprises.
 Methods. The article uses processed by analytical alignment data of pricing methods analysis. Achievement of the objectives was carried out with help of general and special research methods, namely: dialectical approach, analysis and synthesis, systematization and generalization
 Results. Developed classification of pricing models is presented in this research with separation of the transfer pricing methods group, which are an effective tool of international tax planning transparency increasing, taxation stability ensuring and eliminating the possibility of moving profits to other tax jurisdictions. Transfer price formation stages matrix is developed which divides transfer pricing process on five stages: data collection, functional analysis, economic analysis, accounting procedures, reporting. The study tested the possibility of implementation in Ukraine of steps 8-10 of the BEPS plan as relevant for solving problems caused by tax base erosion.
 Conclusions. Developed in the article matrix of the transfer price formation stages will contribute to effective implementation of BEPS steps relating to pricing control.
Highlights
Effective enterprises’ pricing policies should be planned in line with market trends and ensure that the best results are achieved, taking into account available resources. Today it is not enough for retail enterprises just to determine the strategic prospects of pricing policy and establish a reasonable price, it is important to manage its changes promptly, depending on economic conditions changing as well
The goal of this article is to conduct a comprehensive analysis of pricing methods, substantiate integrated approach to transfer pricing in the context of ensuring of participants’ economic interests in transfer pricing process, determine the key factors of transfer pricing applying and develop organizational and methodological measures for the transfer pricing mechanism implementation at Ukrainian enterprises
- a person has the authority to appoint an individual executive body of a legal entity or appoint ≥50% of its collegial executive body or supervisory board; - the sole executive bodies of legal persons are appointed by the decision of one and the same person; - 50% or more of the collegial executive body and / or supervisory board are the same inCdividuals; -Ran individual exercises the powers of an inI dividual executive body of a legal entity; - the poTwers of a sole executive body of legal entitiesEare exercised by the same person
Summary
Effective enterprises’ pricing policies should be planned in line with market trends and ensure that the best results are achieved, taking into account available resources. Today it is not enough for retail enterprises just to determine the strategic prospects of pricing policy and establish a reasonable price, it is important to manage its changes promptly, depending on economic conditions changing as well. Creation of an optimal price at retail business is a complex cost demanding and time-consuming process, that involves large volumes of information analysis It does not stop after once occurring setting of prices for selected market, but it suggests further permanent adjustments of prices and temporary price manipulation programs for solving of set of tasks. Modern consumer, whose purchasing power has dropped significantly, is responsive to price changes, because the price itself plays a decisive role in choosing a product
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