TRANSFORMATION OF TRANSFER PRICING POLICY IN THE CONTEXT OF ESG-ORIENTED BUSINESS STRATEGIES

Анотація

The article examines the transformation of transfer pricing policy in the context of modern challenges in the global economy, particularly the integration of ESG-oriented business strategies. The authors demonstrate that the integration of environmental, social, and governance (ESG) aspects into corporate governance systems is reshaping approaches to transfer pricing analysis, driven by the need to harmonise the financial interests of businesses with sustainable development goals. The article goes on to provide a comprehensive overview of the theoretical underpinnings of ESG metrics, which are progressively emerging as a novel metric for evaluating the efficiency of intra-group transactions. These metrics take into account environmental innovations, social responsibility, and transparency in governance processes. The study demonstrates that the integration of environmental initiatives, such as carbon regulation, renewable energy development, and ecological innovation, presents new challenges for transfer pricing systems. Specifically, it is contended that environmental responsibility introduces complexity to the comparability analysis, necessitating the incorporation of additional factors in functional analysis. Furthermore, social aspects, such as ensuring gender equality, promoting inclusivity, and fostering social justice, necessitate adapting valuation methods for intra-group transactions. The following governance factors have been identified as providing the basis for improving traditional transfer pricing methods: transparency of corporate governance, compliance with non-financial reporting standards (GRI, SASB) and the introduction of digital tools for monitoring transactions. Particular attention is paid to the analysis of regulatory initiatives, such as the OECD transfer pricing guidelines and the Pillar Two concept, which introduces global minimum taxation rules. The article examines the potential adaptation of these rules to the specifics of multinational corporations' activities using ESG approaches. The application of digital tools, including the automation of accounting processes and the utilisation of artificial intelligence for risk modelling, has been demonstrated to enhance the efficiency of monitoring intra-group transactions. The study also emphasises the importance of documenting transfer operations with consideration of non-financial factors, promoting the harmonisation of international transfer pricing practices. The study proposes a conceptual model for integrating ESG metrics into transfer pricing policy, which accounts for the multifactorial influence of environmental, social, and governance indicators on transfer price formation. In order to validate the practical significance of this approach, the case method was used to examine real-world practices of companies such as Tesla, Unilever, Amazon, and others in adapting their transfer pricing policies to the contemporary challenges of sustainable development. The findings emphasise that adopting ESG-oriented approaches to transfer pricing is not only a regulatory requirement but also a tool for enhancing business competitive advantages. The conclusions of the article have practical significance for improving transfer pricing policies, developing risk management methodologies, and ensuring compliance with sustainable development requirements.