Basic Characteristics 1.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 Motives transfer of money; decrease of tax duties; impact on customs tariffs; different risks; other.
Organization for Economic Cooperation and Development Transfer PricingInternational Taxation 30 members
OECD Main Document “ Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations”, 1995 “Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations”, 1995 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 Document 2)Holding Trainings for Controllers 3)Restructuring Tax Administration II Stage: 4)Implementing Transfer Pricing Methods 5)Applying Sanctions for Abuse of Transfer Pricing III Stage: 6) Regulating Transfer Pricing for Non-Material Assets