The thesis is a complex research of theoretical, methodical and practical aspects of transfer pricing accounting. The study substantiates the approaches to improvement of concepts “transfer price” and “transfer pricing” through investigation of the basic intrinsic features of these concepts as well as recommendations related to their additional intrinsic features. The study offers classification of transfer prices according to additional criteria, such as “type of tax control over transfer pricing transaction”, “type of legal form of associations of enterprises applying transfer prices”, “type of economic relations between the enterprises applying transfer prices”. In order to extend the list of economic transactions, in which transfer prices are applied, it is advised to divide them by the type of object of pricing into the following groups: transfer prices for goods, services, intangible assets, and financial assets. Based on the study on the stages of transfer price determination, the typical transfer pricing process at trade enterprises has been defined and systematization of all methods of transfer price determination has been carried out. This has made it possible to identify peculiarities of these methods when they are applied at trade enterprises, to deliver recommendations on how to use current methods of pricing and transfer price correspondence to the arm’s length principle at these enterprises. In order to solve the issue of objective and reliable representation of the transfer pricing process in the accounting system, a conceptual approach to transfer pricing accounting is proposed through definition of such its components as subjects, objects, objectives, and principles as well as division of transfer pricing accounting according to the object of accounting into: accounting for transfer prices transactions and accounting for transfer price determination with application of appropriate methods. Arising from the research undertaken on methodical approaches to accounting for transfer prices transactions, a structural and logical accounting algorithm for such transactions has been suggested which breaks down into primary, current and final accounting; additional analytical level of accounting information has been distinguished; and introduction of additional accounting registers has been advised. Based on the elaborated system of accounts and registers of accounting for transfer prices transactions, the recommendations on company’s financial and tax reports insofar as it refers to transfer pricing are provided. In order to improve the accounting of transfer pricing process, proposals have been made concerning identification of key performance indicators of the company, such as income, expenses, and profitability indicators, by units (commodities) to which the transfer price is being applied. The aforesaid system is based on the peculiarities of current methods of transfer pricing, with the help of which its compliance with the arm’s length principle is established. Studies of control over transfer pricing at trade companies show that there was a lack of clear approaches to such a control procedure. In order to solve this problem, a number of recommendations are made on improving the system of in-house control over transfer pricing; mechanisms for such a control are developed basing on its division into the primary, current and final types; and the information support for tax control over transfer pricing is mapped out. The description of methodical approaches to control over transfer pricing and determination of compliance of the transfer price to the arm’s length principle are given, considering acting tax legislation. Herewith it is determined that the reviewed method for transfer pricing control is relevant for the trading enterprise at the stage of determination of the transfer price and at the stage of reporting on transfer pricing. In the context of improving control over transfer pricing, various approaches to the analysis of price comparability in economic transactions between related and independent parties, which are the basis for application of the arm’s length principle, are investigated.
