Transfer pricing in emerging markets

Abstract

Purpose. The purpose of this article is to study the relevant areas of using transfer pricing as a corporate strategy, a model of commer-cial operations, and a mechanism for managing corporate finances. Methodology. The methodological basis of the study is a set of pro-posed tools and models for researching corporate business opera-tions. Along with a model for analyzing the economic operations of an integrated enterprise based on improving the structural and functional approach and quantitative and analytical tools for func-tions assets risks analysis. The quantitative and analytical tools for the qualitative assessment of business operations of integrated operating assets of developing countries as part of holding-type parent groups have also been improved. Approach. The methodological approach takes into account the general requirements of the legislation of developing countries on the example of the CIS coun-tries. The article describes the results of the systematization of the main characteristics of the transfer and transfer pricing. The authors examine in detail the transfer pricing methods that are most often found in the tax laws of developing countries. On the example of the CUP-method, recommendations on the use of this method in various business operations are described in detail. Findings. The article describes the experience from real practice of applying a methodological approach to the analysis of corporate operations, used by leading world-class consulting companies. The results can be applied both in scientific research of issues related to transfer pricing and in the practice of preparing tax reporting of assets from developing countries