ANALYSIS OF INFORMATION SOURCES FOR TRANSFER PRICING IN THE CONTEXT OF DIGITALIZATION

Abstract

he article analyzes the legislative requirements for the selection of sources of information on comparable uncontrolled transactions and within the framework of building a range of profitability of independent companies that corresponds to the arm's length principle. The possible databases that can be used for benchmarking research are identified, as well as practical recommendations for their use, improving the quality of selection based on the requirements of the Tax Code of Ukraine. The results of this article may be of practical value for enterprises that carry out controlled transactions and are subject to transfer pricing in Ukraine. The expansion of legislative requirements for transfer pricing control stimulates the use of more modern sources of information on comparable prices and companies. However, along with the growing number and complexity of such sources, the problem of choosing the optimal source and parameters of its application arises. The Tax Code of Ukraine is already receiving important updates that directly introduce and require the use of specialized technological solutions for the purposes of controlling various aspects of taxation. At the same time, insufficient attention has been paid to the study of the problems of optimal selection of information sources for the analysis of transfer pricing and controlled transactions, taking into account the challenges of digitalization. The purpose of the article is to determine the main set of optimal and acceptable sources of information on comparable uncontrolled prices and financial performance of comparable enterprises based on professional data base. Research methodology. Both general scientific and special methods of scientific knowledge were used. In particular, the following scientific methods of research were used: dialectical - to substantiate the content of the main provisions; abstract-logical - to determine the essence of an acceptable source of information and the optimal parameters of its use, analysis and synthesis - to identify a set of sources of information for transfer pricing depending on the type of controlled transaction.