Improving transfer pricing in Ukraine using American Experience

Main Article Content

Julia Grinenko
Dmytro Melnychuk
Larysa Mykhalchyshyna
Svitlana Belei
Nataliia Yevtushenko
صندلی اداری

Abstract

The purpose of the present research is to determine the characteristics of transfer pricing and proposals for its improvement, identifying key factors applying transfer pricing and the development of organizational and economic measures for the implementation of the mechanism of transfer pricing in Ukrainian enterprises based on US experience. Due to significant growth of the number of multinationals since 1950, and expanding the geographical environment of their activities caused the increase in the number of studies on transfer pricing. Strengthening external instability greatly affected the formation and increased use of transfer pricing, as well as the use of market prices for the companies is risky. The research is based on the requirements of the fundamental documents of the Organization for Economic Cooperation and Development (OECD) and by the United Nations Tax Committee (UN), International Accounting Standards Board (IASB), Generally Accepted Accounting Principles (GAAP), as well as on empirical data obtained in the process of analysis of reporting of Ukrainian companies.

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Section
Integration System of Education, Science and Production
Author Biographies

Julia Grinenko, Kyiv National Economic University by V.Hetman

Ph.D. Student at the Audit Department in Kyiv National Economic University named after Vadim Hetman. Graduated from Kyiv National Economic University named after Vadym Hetman with honor and obtained qualification Master Degree in accounting and audit, faculty of accounting, the English master program "Accounting and auditing in the management of business activity". In 2017 entered graduate school at Kyiv National Economic University named after Vadym Hetman. In 2017 received The Forensic Expert Certificate issued by the Central Expert Qualification Commission of the Ministry of Justice of Ukraine, qualification in specialties: 11.1. "Investigation of accounting, tax accounting and reporting documents", 11.2. "Investigation of documents on economic activity of enterprises and organizations", 11.3. "Investigation of documents of financial and credit operations". In 2018 received The Auditor’s Certificate (Audit Chamber of Ukraine). She has practical experience in the company as an accountant, auditor and forensic expert. The author of numerous publications and the participant in scientific and practical conferences. Scientific interests: forensic expertise, audit of financial statements, transfer pricing.

Dmytro Melnychuk , Zhytomyr Polytechnic State University

Doctor of Economics, Associate Professor, Professor of Department of Psychology and Social Welfare. He teaches disciplines taught: economics, social and humanitarian policy, human resource management. Scientific interests: economics, social policy, social welfare, humanitarian policy, human capital. ResearcherID ABI-5505-2020

Larysa Mykhalchyshyna, National University of Life and Environmental Sciences of Ukraine

Ph.D. in Economics, Associate Professor, works at the Department of Global Economics of the National University of Life and Environmental Sciences of Ukraine. She teaches the subjects taught at the Department of Global Economics: Agricultural Policy, Livestock Economics. Has practical experience as an expert at the Forensic Research Institute. Scientific interests: market analysis, competitiveness assessment.

Svitlana Belei, Yuriy Fedkovych Chernivtsi National University

Ph.D., Associate Professor. Department of Public, Corporate Finance and Financial Intermediation. Scientific interests: Development of agrarian economy as a paradigm of transformation and integration processes in the conditions of globalization; mechanisms of rural development in the conditions of disproportion of economic growth

Nataliia Yevtushenko, Hryhorii Skovoroda University in Pereiaslav

Ph.D., Associate Professor of Finance, Accounting and Taxation

References

Agarwal, S. (2016). Transfer Pricing Meaning Examples Risks Benefits. Available at: https://www.linkedin.com/pulse/transfer-pricing-meaning-examples-risks-benefits-shivangi-agarwal

Akpojevwa, O. A. (2014). The effects of international transfer pricing on host nations: An overview of developing nations. SCSR Journal of Business and Entrepreneurship (SCSR-JBE), 1(1), 34–41.

CMU (2013). List № 866: On approval of the list of sources of information on market prices for the purposes of transfer pricing. Available: http://zakon4.rada.gov.ua/laws/show/866.

Generally Accepted Accounting Principles (2020). The Financial Accounting Foundation and the Financial Accounting Standards Board. Available: http://www.fasb.org/

Gresik, T. A. (2010). Formula apportionment vs. separate accounting: a private information perspective. European Economic Review, 54, 133–149.

IRS (2020). Electronic Tax Code, Regulations and Official Guidance. US Available: https://www.irs.gov/Tax-Professionals/Tax-Code, Regulations and Official Guidance

KPMG Cutting throught complexity (2011). Globalt ransfer prising prewiev. Global transfer service. February 2011

Mackie‐Mason, J. K. (1990). Do taxes affect corporate financing decisions?. The journal of finance, 45(5), 1471-1493.

Malis, N. I. (2014). New directions of tax control and revenue base of budgets of all levels. Finance. 10. Available: https://www.elibrary.ru/contents.asp?issueid=1141901&selid=20279604.

Malis N. I., & Grundel, L. P. (2014). Transfer pricing as a tool of tax policy: a monograph. Financial University under the Government of the Russian Federation. 235 p.

Model Tax Convention on Income and Capital (2014). OECD Committee on Fiscal Affairs. Available: http://www.oecd.org/

Nepesov K. A. (2007). Tax aspects of transfer pricing: a comparative analysis of the experience of Russia and foreign countries. Walters Clover, 221 p.

OECD (2014). Standard for automatic exchange of financial account information. Available: http://www.oecd.org/

Schjelderup, G., & Sørgard, L. (1997). Transfer pricing as a strategic device for decentralized multinationals. International Tax and Public Finance, 4, 277–290.

Schjelderup, G., & Weichenrieder, A. (1999). Trade, multinationals, and transfer pricing regulation. Canadian Journal of Economics, 32, 817–834.

Tang, R. Y. W. (1979). Transfer pricing practices in the United States and Japan. New York: Praeger.

Tang, R. Y. W. (1992). Transfer pricing in the 1990s. Management Accounting, 73, 22–26.

Tang, R. Y. W. (1993). Transfer pricing in the 1990s: tax and management perspectives. Westport: Quorum Books.

Tang, R. Y. W. (2002). Current trends and corporate cases in transfer pricing. New York: Praeger.

Tax Code of Ukraine (2020). Verkhovna Rada of Ukraine. Available: http://zakon4.rada.gov.ua

Vasilieva M. V., Valinurov T. V., & Proskura E. P. (2013) Methodology, concept and practice of taxation: domestic and foreign experience. Collective monograph: LLC "Buki Vedi".

Yuniasih, N. W., Rasmini, N. K., & Wirakusuma, M. G. (2012). Pengaruh Pajak dan Tunneling Incentive pada Keputusan Transfer Pricing Perusahaan Manufaktur yang Listing di Bursa Efek Indonesia. Jurnal Simposium Nasional Akuntansi Unikal XV.

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