The article examines the theoretical, methodical and practical issues of transfer pricing in the company taxation system. The principles of choosing different methods of transfer pricing, the procedure and features of their application are given: the method of comparative uncontrolled price is based on external market prices; the "cost plus" method determines prices based on cost and profit; the resale price method is based on setting retail prices; the net profit method determines the profit relative to the volume of sales; the profit sharing method allocates the total profit between the parties in international transactions. It has been established that the comparative uncontrolled price method is the preferred method of determination for substantiating the terms of transactions between related parties. It was determined that the choice of transfer pricing method depends on the type of activity of companies, functional profile and other factors. It is proven that the justification of the conditions of transactions depends on the feasibility of the chosen method, which is chosen taking into account the specifics of the transaction, the presence of internal comparative transactions, commercial obligations of the parties to the transactions, and the functional profile of the company. Automated means of calculation for each method are proposed using the examples of individual non-resident legal entities.
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