TRANSFER PRICING MECHANISMS IN THE TAX MANAGEMENT SYSTEM

Abstract

The contemporary global economic environment is characterized by a significant intensification of fiscal oversight, largely driven by the implementation of the OECD Base Erosion and Profit Shifting (BEPS) initiatives. These transformations have redefined the role of transfer pricing, shifting it from a narrowly focused compliance function toward a broader element of corporate governance and tax management. Under conditions of increasing regulatory pressure and transparency requirements, multinational enterprises operating across multiple jurisdictions are compelled to reconsider traditional approaches to intra-group pricing. This challenge is particularly relevant for economies undergoing institutional transformation, including Ukraine, where the alignment of national tax practices with international standards remains an ongoing process. In this context, transfer pricing emerges as a complex and multidimensional phenomenon that integrates elements of financial management, taxation, and strategic decision-making. The relevance of the topic is conditioned by not only the need to ensure compliance with evolving international norms but also the necessity to balance fiscal interests of the state with the operational efficiency of business entities. The growing importance of intangible assets, digital business models, and integrated value chains further complicates the application of conventional transfer pricing methods, raising questions about their adequacy in reflecting real economic activity. The study focuses on the conceptual and methodological aspects of transfer pricing within the system of tax management, emphasizing the need to reassess existing theoretical approaches in light of global regulatory changes. Particular attention is paid to the role of value creation processes in multinational enterprises and the challenges associated with the allocation of profits among related parties. The research also addresses the increasing importance of mechanisms aimed at preventing tax disputes and enhancing certainty in tax relations, including advance agreements and international coordination procedures. Thus, the research highlights the necessity of developing a coherent and adaptive framework for transfer pricing that reflects the principles of economic substance, transparency, and international cooperation. The discussion is centered on identifying the key directions for the evolution of transfer pricing in the modern economic environment, as well as outlining the challenges faced by national tax systems in integrating into the global fiscal architecture.