METHODOLOGICAL TOOLS FOR MAKING MANAGEMENT DECISIONS ON TRANSFER PRICING

Анотація

The article systematises methodological tools for making managerial decisions on transfer pricing. An analysis of domestic scientific works on the study of the list of methodological tools for determining transfer prices is carried out. It is found that transfer pricing researchers in the system of management accounting agree on a list of methods for determining transfer prices, including methods for determining transfer prices on the basis of market prices, on the basis of cost prices determined by marginal/standard/full costs or on a double basis, and on the basis of contract prices. Researchers of transfer pricing in the tax system are united in this approach and work with the methods (comparable uncontrolled price (as sales); resale price; "cost plus"; net profit; profit distribution) recommended by the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations and established by the Tax Code of Ukraine when checking the conformity of the terms of controlled transactions with the arm's length principle. Identify the conditions under which transfer pricing methods are used in domestic practice. The advantages and disadvantages of using certain transfer pricing methods are identified. To test and thoroughly analyse the transfer pricing methods, business operations of an agro-industrial enterprise are developed. The characteristics and limitations of the application of a particular transfer pricing method are identified. These transactions clearly illustrate the characteristics, advantages and disadvantages of using each transfer pricing method to verify the arm's length transfer price. The author demonstrates the need for adjustments in cases where the transfer price or profitability of a controlled transaction is not in line with the arm's length principle. The article emphasises the need for proportional adjustment of the tax base as a means of avoiding double taxation. Taking into account the systematisation of legal and regulatory provisions on transfer pricing, peculiarities, advantages and disadvantages of using certain methods, the author proposes a general scheme for making managerial decisions in the field of methodological management of transfer pricing operations.