Cherevko O. Transfer pricing in terms of Ukrainian tax system

Object - process of the application and regulation of transfer prices in transactions between related parties. Goal - theoretical principles and practical recommendations for improving the use and regulation of transfer prices within the tax system of Ukraine. Methods - semantic analysis, induction and deduction, system-structural analysis, economic-statistical and analytical, factor analysis, dynamic contrast, graphic coefficient method; correlation, regression analysis method and statistical evaluations. Results - proved the phenomenon of transfer pricing and development carried out practical measures for improving the use and regulation of transfer pricing tax system in Ukraine. Novelty - improvements on essence of transfer pricing, which is defined as the establishment of internal corporate prices in the transactions between related parties by pricing goods, services, intangibles and financial assets, insurance rates that are focused on the redistribution of financial resources with appropriate administrative staff motivation and autonomy deepening of divisions. The approaches for choosing a transfer pricing method in each controlled transaction. Profound approach to the analysis and assessment of the risks that arise in the application of transfer pricing by transnational corporations by their isolation from the general set of tax risks. Characteristics are specified on the formation and development of transfer pricing in Ukraine, taking into account the peculiarities of this process from macroeconomics, global economics and the position of the insurer. Ways of improving the relationship between fiscal authorities and taxpayers in the context of transfer pricing. The expediency of implementation experience of developed countries in the context of state control over transfer pricing in national tax practice. Areas of fiscal regulation of transfer pricing are determined. Introduced within the activities of the Main Department of the State Fiscal Service of Ukraine in the Ternopil region, LLC "Tsyfro Trade", LLC "Grant Thornton Legis", and the learning process of Yuriy Fedkovich Chernivtsi National University. Sphere of usage - activities of the State Fiscal Service of Ukraine, the Taxation and Customs Committee of Verkhovna Rada of Ukraine.