TRANSFER PRICING IN THE CONTEXT OF GLOBALIZATION: CHALLENGES FOR ACCOUNTING, AUDIT, AND TAXATION IN UKRAINE

Abstract

Relevance. In the context of Ukraine's open economy, which heavily relies on foreign economic operations, transfer pricing plays a key role in the strategic planning of financial flows within corporate groups. However, the imperfection of national legislation and the insufficient harmonization with international standards, particularly with the BEPS (Base Erosion and Profit Shifting) plan, create conditions for price manipulation, leading to budget losses and distortion of financial reporting. During wartime, these problems are exacerbated by economic instability, sanctions, and limited access to market data. The main challenges remain the lack of transparency in operations, difficulties in determining arm's length prices, limited access to information resources, and the need for harmonization of domestic legislation with international standards, which underscores the relevance of this research.

Purpose of the article is to substantiate the current state of transfer pricing in the context of globalization, identify its challenges for accounting, auditing, and taxation in Ukraine, and develop directions for improving the transfer pricing system.

Methods. The following methods were used in the study: analysis and synthesis; abstraction and generalization (to highlight the key issues in transfer pricing); statistical data analysis; case studies (examining practical examples of fintech companies in Ukraine); expert evaluations; and process modeling (for developing stages of transfer pricing formation at the enterprise level).

Results. The article explores the relevance of transfer pricing in the context of globalization and Ukraine's integration into the global economic space, where it becomes a key tool for managing financial flows of multinational companies. The study analyzes the current challenges in accounting, auditing, and taxation, including the difficulty of determining market prices, limited data access, and insufficient professional qualifications. It identifies shortcomings in national legislation and its misalignment with international standards (especially BEPS), which contributes to abuse and results in budget losses and distorted reporting.

It is determined that transfer pricing, as a mechanism for intra-group transactions, needs improvement through harmonization with the arm’s length principle and OECD standards. Proposed improvement measures include the creation of a national benchmark pricing registry, automation of reporting, simplification of documentation procedures, and enhancement of tax officers' qualifications. An algorithm for establishing transfer pricing within an enterprise has been developed.

Practical value of the study. The research findings can be used in shaping the accounting and tax policy of both enterprises and the state.

Conclusions. Transfer pricing in a globalized environment is a complex phenomenon that significantly affects accounting, auditing, and taxation in Ukraine. The study demonstrates that despite progress in aligning with international standards, especially BEPS, further improvement of the regulatory framework, enhancement of personnel qualifications, and development of analytical infrastructure are needed. The proposed measures — such as the creation of a national pricing registry, automation of reporting, and transparent audit procedures — will contribute to reducing tax abuse and strengthening fiscal stability. Promising areas for further research include the development of digital tools for transfer pricing analysis, assessment of the impact of martial law on transfer operations, and strengthening the role of management accounting in control processes.