Prepared by Anna Ielisieieva, 4th year student,

International Economics,KROK University for Economics and Law

1. Economic Essence of Transfer Pricing

2. Transfer Pricing Regulation in Developed

Countries

3. Transfer Pricing Regulation in Ukraine

Current Challenges

Recommendations

Basic Characteristics1.Regulation inside a company.

2.Meeting particular needs.

3.Generation of the inner profit rate.

4.Influence on macroeconomic

indicators.

5.Manipulation by a TNC.

TNC’s Motivestransfer of money;

decrease of tax duties;

impact on customs tariffs;

different risks;

other.

Organization for Economic Cooperation and Development

Transfer Pricing International Taxation

30 members

OECD Main Document

The Arm’s Length Principle;

Transfer Pricing Methods;

Administrative Procedures;

Instructions for Tax Authorities;

Advance Pricing Arrangements;

Transfer Pricing of Non-Material Assets &

Services.

No Regulation System

Some Legislative Provision:

the Law of Ukraine "On Corporate Income Tax"

the Law of Ukraine "On the Value Added Tax”Resolution of the National Bank of Ukraine

№597 "On transfer of funds in national and foreign currency to non-residents for Certain Transactions”

I Stage:1)Publishing Special Legal Document2)Holding Trainings for Controllers3)Restructuring Tax Administration

II Stage:4)Implementing Transfer Pricing Methods5)Applying Sanctions for Abuse of Transfer Pricing

III Stage:6) Regulating Transfer Pricing for Non-Material

Assets