Міжвідомчий Науково-методичний збірник
"Криміналістика і судова експертиза"
ISSN: 0130-2655
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I. Grynenko; Yu. Grynenko


Transfer pricing is due to the international operationsʼs expansion of multinational corporations, in practice concerns the pricing of goods, services and intellectual property transmitted across borders within corporate networks. The prices at which the transfer of such assets takes place determines the income levels of both parties and, thus, the tax base of the countries concerned. In theory, if the calculated transfer price provides a reasonable distribution of profits, the tax authorities of both countries receive a fair share of tax revenues. However, in practice there is a possibility of minimization and manipulation with the deduction of profit points.

The tax control of transfer pricing is based on the Armʼslengthprinciple principle, an international standard agreed upon by the member states of the Organization for Economic Cooperation and Development and non-member countries (more than 70 countries of the world) as recommended by use for the establishment of transfer prices for tax purposes, which provides for the increase of tax liabilities of related parties to the level of tax liabilities of unrelated persons, subject to the compliance of the trader or financial conditions of their transactions.

The OECD guidelines on transfer pricing for multinational companies and tax services, the main norms of which have been implemented by the Ukrainian tax code, are the main documentary guidance document in the field of transfer pricing tax regulation.

The main purpose of the article is to summarize the expert practice and systematize the government regulation for the development of general algorithms of controlled operationsʼs expert study.

General algorithm of controlled operations research, will allow to significantly reduce labor intensity and terms of conducting research. The field of application is in expert practice during conducting of expert examinations and expert researches on the expert specialty 11.1 «Investigation of documents of accounting, tax accounting and reporting».