TRANSFER PRICING IN FOREIGN ECONOMIC TRANSACTIONS BASED ON FORWARD; FUTURES AND SPOT CONTRACTS

Introduction. In the context of globalization; transfer pricing in forward; futures and spot contracts is becoming increasingly relevant. It is necessary to develop methods that take into account the volatility of market prices and the specifics of foreign economic activity to adjust prices in such contracts. The lack of clear approaches to assessing the compliance of contracts with market conditions creates risks of tax disputes and a decrease in the competitiveness of companies. Purpose. The article is aimed at developing recommendations on ensuring compliance of the terms of forward; futures and spot contracts with the arm's length principle in transfer pricing. Materials and methods. The study used normative legal acts and scientific works on transfer pricing. Methods of generalization; systematization; induction; deduction; abstraction; analysis and comparison for the development of methodological approaches to the assessment of transfer prices are applied. Results. The article discloses the features of transfer pricing in foreign economic transactions with forward; futures and spot contracts. The correlation between spot prices and prices in forward and futures transactions has been established; which allowed to substantiate a new methodological approach to pricing. An in-depth analysis of the legislative and regulatory framework for the implementation of the principles of transfer pricing in transactions with forward; futures and spot contracts; the application of the “arm's length” principle was carried out. The correlation between spot prices for goods and prices in forward and futures transactions allowed us to justify a new approach to pricing. Particular attention is paid to the justification of the use of market spot prices in the study of pricing in controlled transactions under forward contracts and adjustment methods to ensure the accuracy and compliance of prices. The compliance of contracts with the criteria for their recognition as forward; in particular; regarding the immutability of essential conditions and compliance with the requirements of the notification on the conclusion of contracts; was also analyzed. The company has solved methodological problems related to compliance of contracts with the forward criteria; use of market spot prices; adjustment of forward prices depending on the period between the conclusion of the contract and transactions; as well as mapping of provisions for reimbursement of future expenses and hedging; which ensures greater accuracy and efficiency in transfer pricing. Prospects. Further research should be aimed at studying the impact of new technologies; in particular artificial intelligence; on transfer pricing processes and financial risk management.