Risk Assessment Methods of Transfer Pricing

Abstract

Transfer pricing is one on the greatest problem of the global system of taxation and therefore the efficient TP tax control is of special importance. As the risk-oriented approach allows to improve the TP tax control, tax administrations as well as businesses should apply and develop it for the timely risks identification. This assumption is based on the review of foreign and domestic scientific literature provided in this article. This study aims to analyze the significance of TP risk management system and its impact on the TP tax control and voluntary tax compliance as well as to develop proposals on the TP risks assessment methods, focusing on Ukrainian tax regulation as well as the OECD and the EU tax framework. The research methods include systematic and comparative analysis of scientific literature, deduction, induction, analysis, synthesis and systems approach. To fulfill the objective of this study the analyses of legislative regulation of the TP control at both the international and the country level is provided, focusing on the stage of the monitoring of the controlled transactions. For the enhancement monitoring stage of the TP control the algorithm for the risk identification and assessment for the monitoring of controlled transaction (CT) is suggested. The study also provides for the methodology on comparison of the profitability of taxpayers with the average in the industry and methodology for building the TP risks matrix. The study results revealed the significance of the TP risks management processes standardization that allows its automatization and could contribute to the TP tax control strengthening as well as an TP compliance improvement. The prospects for future research could be focused on development of an algorithm for comparing the prices of CT with the quoted prices for raw materials.