INFORMATION AND ANALYTICAL SUPPORT FOR TRANSFER PRICING CONTROL IN UKRAINE

Abstract

The article is devoted to the study of information and analytical support for transfer pricing tax control in Ukraine as a key instrument for counteracting tax base erosion under conditions of globalization, digitalization, and martial law. The relevance of the topic is driven by the growing role of multinational enterprise groups in generating tax revenues, the increasing complexity of business chains, enhanced capital mobility, and the need to ensure a fair allocation of the tax burden among jurisdictions. In the context of limited public financial resources, the ability of tax authorities to effectively apply analytical tools to identify risky transactions and substantiate control decisions becomes particularly important. The purpose of the article is to define the content and specific features of the information and analytical component of transfer pricing tax control and to assess its impact on the effectiveness of control procedures and the reduction of tax risks. The study employs methods of analysis and synthesis, comparative, logical, and systemic approaches, as well as abstraction and structuring to develop a comprehensive vision of the modern control model. It is established that transfer pricing tax control in Ukraine has evolved from formal price verification to a comprehensive analytical process focused on assessing the economic substance of transactions, analyzing value creation chains, and examining the allocation of functions, assets, and risks among related parties. The decisive role of information and analytical support is substantiated, as it is based on the integration of tax, customs, open, and international information sources and is implemented through a risk-oriented approach to taxpayer selection. The SWOT analysis made it possible to identify the strengths of the system (regulatory clarity, formalization of procedures, implementation of digital tools) and its weaknesses (limited possibilities for comparability analysis under martial law, high compliance costs), as well as to outline threats and directions for further development. The PEST analysis revealed key political, economic, socio-cultural, and technological factors influencing the organization of control. The practical value of the results lies in their potential use for improving analytical procedures, enhancing the effectiveness of risk-oriented monitoring, and strengthening tax risk management.