Dzyuba P. Transfer Pricing in the Financial System of TNC.

The thesis is devoted to the research of transfer pricing as the most efficient transfer mechanism in the financial system of TNC. Economic nature of transfer pricing is being explored, functions and types of transfer prices are found out, approaches to transfer pricing research in the contemporary scientific literature are analyzed. The research of the variety of existing transfer prices types enabled the author to suggest two new classification criteria: according to the type of transfer pricing object (transfer prices for goods, services and production factors) and according to the character to international trade relation (trade and nontrade transfer prices).The author's approach to the structure of the financial system of TNC is suggested, the location of transfer pricing is pointed out and its interrelation with other financial system elements are determined. Two major components of the TNC financial system: transfer mechanisms and financing sources are often interrelated.The internal structure of transfer pricing process has been defined as subject (any element of the institutional part of the TNC financial system), object (goods, services and production factors) and target (transfer price itself that can vary according to the object transfer pricing object). 8 directions of modern transfer pricing literature development have been discovered. The peculiarities of each direction are discovered.Potential directions of TNC transfer pricing policy under tax and tariff constraints and under their absence in trading countries are found out. The analysis of transfer pricing while exporting to Ukraine and from Ukraine by interrelated firms has been carried out. The potential TNC transfer pricing decision matrix has been worked out on this basis and respective recommendations for Ukrainian foreign economic policy are proposed.Systems of transfer pricing regulation in developed countries are researched (the example of the USA and OECD principles). The author examines the arm's length principle of transfer pricing, transfer pricing methods and advance pricing agreements. Existing element of the transfer pricing regulation system in Ukraine are researched. Recommendations regarding the introduction of the adequate system of transfer pricing regulation in Ukraine are provided