ACCOUNTING AND TAX CONTENT OF TRANSFER PRICING

The article examines the essence and nature of the transfer pricing category. The duality of the meaning and content of transfer pricing is substantiated. A critical analysis of the scientific literature was carried out on the subject of the interpretation of the understanding of the essence of transfer pricing in the system of accounting management of the business entity. It was noted that the vast majority of researchers of transfer pricing as a management accounting tool did not take into account the nature of the scale of activity of the business entity that implemented the transfer pricing management system — the placement of responsibility centers between which assets are exchanged, under the jurisdictions of different countries with different tax regimes. The peculiarities of transfer pricing as a management accounting tool are determined, namely: the nature of the emergence due to the separation of responsibility centers and the movement of assets between responsibility centers; a factor contributing to the resource provision of responsibility centers; object of making strategic management decisions. The nature of the transfer pricing system in the taxation system is considered. It was found that the use of transfer pricing by holding structures in the process of exchanging assets between centers of responsibility located territorially in different countries is aimed at optimizing taxation. The construction of a model of transfer pricing in the accounting and taxation system was carried out, according to which transfer pricing should be considered in an indivisible system of accounting and taxation and aim to increase the efficiency of the functioning of separate business units (responsibility centers) and ensure the determination of transfer prices for moving material flows between them with mandatory compliance with tax legislation.