Documentation of Transfer Pricing Transactions in the Accounting System of Multinational Enterprise Groups

Tetyana Storozhuk and Artem Morhunenko
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Tetyana Storozhuk: State Tax University, Irpin, Ukraine
Artem Morhunenko: State Tax University, Irpin, Ukraine

Oblik i finansi, 2025, issue 1, 15-23

Abstract: External factors and the complexity of the internal organizational structure can significantly affect the collection of evidence (information), which is the basis for assessing the compliance of controlled transactions with the arm's length principle by participants in multinational enterprise groups (MEGs). The article aims to improve the system of accounting and assessment of intragroup transactions of MEGs regarding the compliance of controlled transactions with the arm's length principle by developing document forms for reflecting information on business transactions. An analysis of scientific publications and transfer pricing practice indicates the need for accurate identification of analytical information and financial reporting indicators when assessing potential controlled transactions of foreign economic activity and determining the features of the application of transfer pricing methods based on the use of the profitability indicator. The article develops accounting registers to reflect information on intragroup transactions, including those that can be defined as controlled, for consistent assessment at the time of transactions and during the reporting preparation. This will provide a comprehensive analysis of the impact of external factors on the conditions for implementing controlled transactions that arise between group members, as well as their further minimization based on strategic management at the parent company level. A form of a register of segmented financial indicators that directly or indirectly relate to transfer transactions was proposed, subject to an agreed group policy and considering the impact of external factors caused by the economic situation in the country or the world. The proposed approach to organizing accounting and assessing the compliance of controlled transaction conditions with the arm's length principle based on improving the existing documentation system clarifies the sequence of actions within the MEGs when forming a transfer pricing policy.

Keywords: accounting; intragroup transactions; controlled transactions; transfer pricing; documentation (search for similar items in EconPapers)
JEL-codes: E64 F23 H21 H26 M41 M42 (search for similar items in EconPapers)
Date: 2025
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Persistent link: https://EconPapers.repec.org/RePEc:iaf:journl:y:2025:i:1:p:15-23

DOI: 10.33146/2307-9878-2025-1(107)-15-23

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