THE ROLE OF TRANSFER PRICING IN FORMING THE MODEL OF TAX BEHAVIOR

Models of tax behavior (tax planning, normal tax payment method and tax evasion) have a significant impact on the economy of business entities and the state as a whole. Tax planning, as one of the models of tax behavior, is a risk of reducing tax revenues to the state budget and increasing the payer's profit by reducing the tax base due to the use of transfer prices. Statistics show that the globalization of economic processes leads to an increase in foreign economic activity and the increasing use by economic entities of the mechanism of aggressive tax planning, in particular the use of transfer prices. The purpose of the article is to analyze the use of transfer prices by business entities and to determine their place and role in the tax planning of international corporations. According to the results of the study, it was established that transfer pricing, due to its specificity, appears to be an effective mechanism of aggressive tax planning, which is used by associated enterprises in order to maximize their profits by transferring them to low tax jurisdictions. The conducted analysis showed a tendency to increase the volume of controlled transactions during the entire period of validity of transfer price control norms in Ukraine. Using the matrix of paired Pearson correlation coefficients, the relationship between controlled operations and the profits of business entities is determined, as well as the impact of these indicators on the gross domestic product. It was determined that transfer pricing, with the use of aggressive mechanisms, is a legal act and an element of the accounting policy of a business entity and a tool for profit management in groups of companies to optimize income tax.