TRANSFER PRICING AS MECHANISM OF TAX PAYMENT CONTROL

Background. The scientific article is devoted to the pressing question of the transfer pricing in Ukraine as a mechanism of tax payment control. Rules of transfer pricing nowadays are actively used in many countries, that is why an improvement of tax legislation of Ukraine in part of the transfer pricing is new method of filling the budget including closing ways for avoiding taxation. Review of scientific sources. The questions of the transfer pricing was studied in the works both of domestic and foreign scientists. The transfer pricing is studied by scientists in two aspects. The first aspect is internal according to which the transfer pricing is an effective enough instrument of the internal planning and management. The second one is tax aspect which somehow is result of the first one. Tax aspect of the transfer pricing for the Ukrainian economy is new, and consequently, not enough investigated. Therefore the purpose of the article is describing essence of the transfer pricing mechanism of tax payment control, analysis of category of uncontrolled economic operations, methods of price determination of the controlled operations, aspects of tax control of the transfer pricing. Results. It was found out that tax control of the transfer pricing is based on the principle of "prolate hand" ? international standard, ratified by the states ? members of the Organization for economic co-operation and development (the OECD) and countries which are not members of this organization, as recommended for the use for establishment of transfer prices for tax necessities. This principle implies the increase of tax obligations of the related persons to the level of tax obligations of the unrelated persons on condition of accordance of commercial and/or financial terms of operations done by them. Transfer pricing for taxation is a system of determination of ordinary cost of commodities and/or results of works (services) in operations, acknowledged as controlled ones. Conclusion. Thus regulation of questions of tax control of the transfer pricing is carried out taking into account international standards and has fiscal character, but on this stage of development of the Ukrainian tax system is justified.