Universal Journal of Accounting and Finance 10(1): 219-230, 2022 http://www.hrpub.org
DOI: 10.13189/ujaf.2022.100123
Transfer Pricing Documentation: Globalization and
Regional Optimization
Svitlana Y. Korol
1,*
, Olena I. Nykyforuk
2
, Ulyana V. Pelekh
3
, Nataliia S. Barabash
4
,
Olha M. Romashko
1
1
Department of Accounting and Taxation, Faculty of Finance and Accounting, Kyiv National University of Trade and Economics,
Ukraine
2
Department of Infrastructure Development of SO Institute for Economics and Forecasting, 26 Panasa Myrnogo Street, Ukraine
3
Department of Accounting and Audit, Economic Faculty, Ivan Franko National University of Lviv, Ukraine
4
Department of Economics and Business Finance, Faculty of Economics, Management and Psychology,
Kyiv National University of Trade and Economics, Ukraine
Received October 7, 2021; Revised November 19, 2021; Accepted December 13, 2021
Cite This Paper in the following Citation Styles
(a): [1] Svitlana Y. Korol, Olena I. Nykyforuk, Ulyana V. Pelekh, Nataliia S. Barabash, Olha M. Romashko , "Transfer
Pricing Documentation: Globalization and Regional Optimization," Universal Journal of Accounting and Finance, Vol.
10, No. 1, pp. 219-230, 2020. DOI: 10.13189/ujaf.2022.100123.
(b): Svitlana Y. Korol, Olena I. Nykyforuk, Ulyana V. Pelekh, Nataliia S. Barabash, Olha M. Romashko (2022). Transfer
Pricing Documentation: Globalization and Regional Optimization. Universal Journal of Accounting and Finance, 10(1),
219-230. DOI: 10.13189/ujaf.2022.100123.
Copyright©2022 by authors, all rights reserved. Authors agree that this article remains permanently open access under
the terms of the Creative Commons Attribution License 4.0 International License
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.
Keywords Base Erosion, Corporate Income Tax,
Developing Countries, Foreign Direct Investment,
Inequality, International Taxation, Profit Shifting, Tax
Avoidance, Tax Havens
JEL Classifications: F21, F23, H25.
1. Introduction
The world economic system is in a deep crisis and,
according to preliminary estimates of some researchers, the
negative consequences of it are much greater than the
economic collapse of 2008-2009. The contraction of the
world economy in 2021 is expected to be 4.4%. Further
stratification of society by income categories is projected
[1]. The negative economic consequences of the
COVID-19 pandemic were large-scale job cuts due to plant
shutdowns and various restrictions imposed by lock-down.
This has particularly affected those who did not have