Kateryna Pugachevska

The subject of the scientific work is analysis of the essence of the “transfer pricing” concept. It has been proven that transfer pricing is an economic and legal tool used by business entities for their tax burden optimization.

It has been concluded that the concept “transfer price” means the price generated by multinational corporations in the process of commercial activity between the affiliated companies located in different countries and, correspondingly, different tax jurisdictions. In essence, transfer pricing means intra-company pricing of goods transferred between the enterprise subdivisions located in different countries. Base erosion by means of transfer pricing can be performed not only based on the price manipulating by the affiliated companies, but also as a result of manipulating incomes and expenditures. The latter is accompanied by the financial resource withdrawal outside the national economy and its concentration in the low taxation jurisdictions.

Transfer pricing bears serious risks both for an individual country and for the world economy. Contractual freedom of transnational corporations and industrial and financial groups cannot be unlimited regardless of the principle of freedom of contracts in the private law relations. Economic activity of such business entities must subject to a strict control on the part of the country. In the process of transfer pricing tax control, the controlling state agencies are intended to prevent the decrease of tax liabilities by shifting the income to low tax jurisdictions by taxpayers.

In the context of neo-protectionism and in terms of WTO membership, regulatory mechanisms for promoting the national producer and country’s external expansion require an institutional basis. This paper primarily aims to explore the resource and institutional component in promoting Ukraine’s exports to Chinese market and to identify the level of Ukraine’s export promotion system effectiveness based on combinatorial approach, which includes the calculation of quantitative indicators of foreign trade in the form of international production and marketing cooperation and estimation of qualitative parameters of export promotion effectiveness. The empirical findings indicate following: high dynamism of increasing mutual trade volume; enlargement of trade flows asymmetry caused by the negative trade balance of Ukrainian economy; limited list of commodity groups of Ukrainian exports in mutual trade with China with stable relative advantages; dominance of low-value-added commodities among export priority groups; absence of beneficial effect of such a factor as “long-term partnerships” in the mutual trade flow. The paper reveals that national export promotion system in Ukraine can be characterized by low efficiency and strong potential for growth. The authors emphasize the importance of intensifying the projects and mechanisms of financial and investment support for exporters with increasing the level of their innovative orientation. Prospects for further research in this area are as follows: the assessment of macroeconomic effects from the introduction of export promotion tools for the national economy of countries of origin of goods and importing countries; detection of anticompetitive risks in the implementation of selective support programs for exporters.