ГЕНЕЗА НОРМАТИВНО-ПРАВОВОГО МЕХАНІЗМУ ДЕРЖАВНОГО РЕГУЛЮВАННЯ ТРАНСФЕРТНОГО ЦІНОУТВОРЕННЯ В УКРАЇНІ

The genesis of the regulatory and legal mechanism of state regulation of transfer pricing in Ukraine reflects profound transformations of the national economic system caused by the transition from an administrative-command to a market-oriented model of economic management, as well as by the country’s gradual integration into the global economic and tax environment. For a long time, transfer pricing remained outside the focus of state regulatory priorities due to limited cross-border activity, weak institutional capacity, and the predominance of short-term fiscal objectives. However, the expansion of multinational business structures, the growing scale of intra-group transactions, and the risks of tax base erosion necessitated a conceptual rethinking of approaches to tax control and regulatory intervention in pricing between related parties. Purpose. The purpose of the article is to provide a comprehensive scientific understanding of the genesis of the regulatory and legal mechanism of state regulation of transfer pricing in Ukraine in the context of the evolution of the national tax system and the country’s integration into the international tax space. Methods. The research is based on a combination of general scientific and special methods, including the historical method to analyze the stages of formation and transformation of transfer pricing regulation, the institutional approach to assess changes in regulatory paradigms, comparative analysis to identify the convergence of Ukrainian legislation with international standards, and the method of scientific generalization to formulate theoretical conclusions. Results. The study reveals the evolution of transfer pricing regulation in Ukraine from fragmentary and indirect control based on the concept of «ordinary price» to an institutionalized, risk-oriented regulatory mechanism grounded in the arm’s length principle. It is shown that the adoption of the Tax Code of Ukraine became a critical turning point that enabled the implementation of specialized transfer pricing instruments, including the identification of controlled transactions, the formalization of pricing methods, and the introduction of documentation requirements. Particular attention is paid to the impact of international initiatives, especially the BEPS Action Plan, which significantly complicated and deepened the national transfer pricing framework through enhanced transparency, functional analysis, and multi-tiered reporting. The adaptive and evolutionary nature of regulatory changes is substantiated, demonstrating their reactive response to emerging tax planning practices and global economic transformations. Conclusion. It is concluded that the contemporary regulatory and legal mechanism of transfer pricing in Ukraine has evolved from a predominantly fiscal tool into a complex element of tax policy aimed at ensuring tax fairness, transparency, and alignment with international standards. At the same time, the increasing complexity and dynamism of regulation highlight the need for further theoretical and applied research focused on balancing fiscal interests with tax neutrality, stability, and proportionality in the context of digitalization, the growing role of intangible assets, and ongoing globalization processes.