Implementation of BEPS principles into the national model of state regulation of transfer pricing in Ukraine

The subject of the study is the implementation of the BEPS principles into the national model of state regulation of transfer pricing in Ukraine.The purpose of the study is an in–depth analysis of the process of implementing the principles of the BEPS Action Plan into the national model of state regulation of transfer pricing in Ukraine.Research methods. The article uses the dialectical method of scientific knowledge, the method of analysis and synthesis, the comparative method, and the method of data generalization.Results of the work. The article examines the process of implementing the principles of the BEPS Action Plan into the national model of state regulation of transfer pricing in Ukraine in the context of globalization, the growing role of transnational corporations, and increased capital mobility. The institutional and regulatory prerequisites for the transformation of Ukrainian tax legislation in connection with joining the BEPS Inclusive Framework and harmonization with OECD recommendations are revealed. The evolution of the arm’s length principle in Ukrainian transfer pricing practice is analyzed, with a focus on deepening functional and comparative analysis, as well as on the priority of the economic substance of transactions over their legal form.Conclusions. The implementation of the BEPS Action Plan principles into the national model of state regulation of transfer pricing in Ukraine is systemic and multidimensional in nature and is accompanied by a change in the conceptual foundations of tax control. The study made it possible to comprehensively analyze the transformation of Ukrainian legislation and law enforcement practice in the direction of the priority of the economic substance of transactions over their formal and legal registration, strengthening the role of the arm’s length principle and deepening the methodology of functional and comparative analysis. As a result, transfer pricing is gradually becoming a tool for ensuring a fair distribution of the tax base in accordance with the real creation of economic value within transnational groups. The analysis of the implementation of actions 8–10 and action 13 of the BEPS Plan has shown a significant increase in the level of tax transparency, in particular through the introduction of a three–tiered documentation system and the development of a risk–based approach to tax control. At the same time, it was established that the effectiveness of these changes largely depends on the institutional capacity of regulatory authorities, the quality of analytical tools and professional training of personnel, as well as on the ability of the state to ensure a balance between strengthening fiscal control and maintaining a favorable and predictable business environment. The limited practice of applying advance pricing agreements and the lack of relevant comparative data remain factors that hinder the full realization of the potential of BEPS standards in Ukrainian conditions. The prospects for further scientific research should be linked to the analysis of the practice of applying transfer pricing rules, assessing the effectiveness of risk–based tax control models, and studying the possibilities of developing the institution of advance pricing agreements in Ukraine. An important direction is also the study of the impact of digitalization of the economy on the evolution of transfer pricing.