Transfer pricing as a means of the state tax base optimization

  • A. Krutova Kharkiv State University of Food Technology and Trade
  • O. Nesterenko Kharkiv State University of Food Technology and Trade
  • M. Levina Institute of Educational Analysis
Keywords: pricing methods; transfer pricing; tax base erosion; profit shifting; tax jurisdiction; related persons; arm’s length” price principle.


This study is aimed at development of the theoretical foundations of transfer pricing mechanism implementation at Ukrainian enterprises. Methods. The article uses processed by analytical alignment data of pricing methods analysis. Achievement of the objectives was carried out with help of general and special research methods, namely: dialectical approach, analysis and synthesis, systematization and generalization Results. Developed classification of pricing models is presented in this research with separation of the transfer pricing methods group, which are an effective tool of international tax planning transparency increasing, taxation stability ensuring and eliminating the possibility of moving profits to other tax jurisdictions. Transfer price formation stages matrix is developed which divides transfer pricing process on five stages: data collection, functional analysis, economic analysis, accounting procedures, reporting. The study tested the possibility of implementation in Ukraine of steps 8-10 of the BEPS plan as relevant for solving problems caused by tax base erosion. Conclusions. Developed in the article matrix of the transfer price formation stages will contribute to effective implementation of BEPS steps relating to pricing control.


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How to Cite
Krutova, A., Nesterenko, O., & Levina, M. (2019). Transfer pricing as a means of the state tax base optimization. Fundamental and Applied Researches in Practice of Leading Scientific Schools, 31(1), 100-107.