Transfer Pricing Documentation: Globalization and Regional Optimization

Abstract

The study was conducted in order to assess and analyse the impact of globalization and regional optimization on the activities of economic entities that are required to prepare transfer pricing documentation. The methodological background of the study involved the following methods: generalization, explanation, grouping, induction and deduction, as well as analysis and synthesis, which were used to clarify the main scientific categories of research and substantiate the research results. Methods of schematic and graphical representation were used to visualize analytical data, formulate assumptions and substantiate the obtained results. The main focus of the study is on the analysis of the causes of global economic risks and the role of transfer pricing documentation, whose quality will help mitigate the negative consequences of undesirable events for the global economic system. The study found that not all countries apply the international instrument — Multilateral Convention to Implement Tax Treatment Related Measures to Prevent BEPS (MLI). Many countries that have started to use MLI reporting, have no uniform standardized rules for the preparation of transfer pricing documentation. The legislation only defines the list of information to be submitted by taxpayers, provided that the results of their business activities meet certain criteria. The development of a unified methodology for valuing financial assets for tax purposes and preventing their use in illegal financial transactions are the promising areas for further research.