DOI: https://doi.org/10.33994/kndise.2019.64.67
Yu. Hrinenko; I. Hrinenko; M. Polennikov
One of the main tasks of the forensic economic examination for transfer pricing is the process of finding and determining the comparability of controlled operations, without which it is impossible to determine the fact of the compliance of the conducted controlled operation on «the Arm’s length principle». The basic component of this search is available and correct information in the form of any information databases and other public sources of information.
Verification of the use of the enterprise by the most appropriate method of transfer pricing by the results of functional analysis as well as the application of methods for prioritization is a procedure that depends and is fully related to the availability of complete and reliable information about prices.
Public information sources contain price information that can be used to determine comparable prices. The list of specialized commercial publications for the purpose of transfer pricing includes – a monthly newsletter «Review of prices of Ukrainian and world commodity markets»; informational and analytical product «Commodity Monitor. Ukraine»; information and analytical product «Digest of commodity prices in world markets»; the head of the State Fiscal service of Ukraine; the official site of the Ministry of Agrarian Policy.
The information contained in the commercial databases Orbis, Amadeus, Ruslana (VanDeek), Onesourse TP (Thomson Reuters), BloombergProfessional (Bloomberg), Spark (Interfax) is publicly available and can be used with an analysis of comparability in order to establish the condition of controlled operations on «the Arm’s length principle».
It should be noted that the main thing that should reflect any source of information is the presence of arguments that will provide comparability to assess and justify compliance with the conditions of the conducted controlled operation on «the Arm’s length principle». Key words: judicial-economic examination, transfer pricing, informative sources, databases.
