Theoretical-conceptual and scientific-applied dominants of transfer pricing policy for economic entities

Abstract

Introduction. Through the adept use of transfer pricing, companies can optimize their costs, minimize various types of risks, maximize profits, and gain tangible competitive advantages. At the same time, in the context of increased fiscal control and constant changes in the international tax environment, adherence to fiscal-regulatory requirements regarding transfer pricing by economic entities gains special importance. Therefore, companies need to develop, implement, and continuously modernize their own corporate transfer pricing policy, as it not only contributes to overall financial success but also strengthens tax security and business reputation of complexly organized and integrated business structures. This highlights and enhances the practical value of relevant scientific research. Objective. The aim of the article is to systematize, generalize, and develop theoretical-conceptual and scientific-applied foundations of the transfer pricing policy of entrepreneurial entities in the contemporary business environment. Method (methodology). The research methodology encompasses a critical systematic analysis of numerous scientific works to understand existing scientific theories and approaches to transfer pricing policy, including the use of comparative analysis to compare different definitions of its essence, graphical method, as well as methods of synthesis, induction, and deduction – in elucidating the targeted orientation, principles of construction, and functional purpose of the said policy. Results. Based on the analysis of a number of definitions of the transfer pricing policy of economic entities by broad and narrow scientific approaches, a proprietary definition of this term is proposed, characterized by universality and addressing identified deficiencies in similar definitions. In the context of deepening and modernizing the theoretical-conceptual foundations of companies' transfer pricing policy, an author's vision of the goals and tasks, principles of formation, and functional purpose of the transfer pricing policy of companies with a complex organizational structure and business associations is proposed. Scientific-applied recommendations on the development, implementation, and practical realization of an effective transfer pricing policy for entrepreneurial structures, which are advisable to follow in the proposed logical sequence, are formulated.