FORMATION OF TRANSFER PRICING ON THE COMPLIANCE BASIS TO SOCIAL RESPONSIBILITY PRINCIPLES

Abstract

The article summarizes: legislative aspects of transfer pricing regulation for business entities of Ukraine; organization and methods for transfer price formation; functional features of transfer pricing processes. The essence of the concepts "transfer pricing", "transfer price" according to normative and journalistic sources is generalized. Peculiarities of stage formation realization within technological cycles of production for the certain production (service) are considered, practice of managing these processes in order to optimize mandatory payments to the budget, a rational approach to regulate the tax burdenAn important element of work with transfer pricing is accounting and taxation legal framework observance, regulatory and legal documenting transactions system, that should be reflected in special reporting, the purpose of which is to monitor compliance with transfer pricing principles. The effectiveness of calculating sales profitability at transfer pricing stages of using usual prices, that calculated on the "outstretched arm" principle is valuated. Main tasks of transfer pricing are generalized, such as: the tax burden optimization, payment and settlement system rationalization, working capital attracting for progressivebalanced of business development, market share expanding, attracting highly qualified specialists, diversifying risks (including currency), introducing of new technologies,investment attractiveness improving of the company (the region of its main activity), material incentives for employees and others. The issue of researched operations documenting for domestic enterprises, the legislative changes impact on accounting and reporting organization on transfer pricing indicators is revealed. Modern Ukrainian legislation constantly monitors the practice of transfer pricing situation, supporting the policy of social responsibility of enterprises regarding the appropriate profitability level of such operations. Despite the already sufficient experience of enterprises in the transfer pricing system, there are constantly new unforeseen or unfinished issues of practical application for transfer pricing. Constant changes in the legislative regulation of this issue play a negative role. Alternatives of analytical accounting for gradual price formation on the basis of social responsibility principles observance forbusiness are substantiated. The expediency of systemic transparent state control over the transfer pricing processes for transactions that are financial monitoring objects (without interfering in full-fledged business entity activity) has been confirmed. Such control should fully disclose both methodology and organization for transfer pricing processes in legislation.