Legal regulation of liability for violation of transfer pricing requirements

Анотація

Problem setting. Given that transfer pricing is a rather complex legal phenomenon, its application is characterized by a number of features, in practice there are often violations of tax legislation on transfer formation. Analysis of recent research. It is significant that the legal regulation of liability for violations of tax legislation and transfer pricing have been the subject of research by many scholars, in particular, such as: O. Dmytryk, D. Kobylnik, A. Kotenko, M. Kucheryavenko, O. Makukh, M. Mishin, E. Smychok and others. At the same time, the study of legal regulation of liability for violation of transfer pricing requirements was almost not conducted. In view of the above, the purpose of the article is to study the legal regulation of liability for violation of the requirements of transfer education. Article’s main body. In the article the author analyzes the modern legal regulation of liability for violation of transfer pricing requirements. Emphasis is placed on the need to improve the updated concept of financial responsibility by consolidating negligence as a possible form of guilt in tax offenses, determining the content of the assessment categories. Conclusions. It is noted that the state regulation of transfer pricing should be aimed not only at resolving issues of replenishment of the state budget by increasing tax revenues by reducing "loopholes" in the form of transfer prices, but also to maintain market relations and improve the efficiency of companies and their divisions.

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