Transfer Pricing

Major: Business, Trade and Exchange Activities
Code of subject: 6.076.02.E.072
Credits: 5.00
Department: Ecological Politics and Environment Protection Management
Lecturer: Kosovska Vira Vasylivna
Semester: 7 семестр
Mode of study: денна
Мета вивчення дисципліни: formation of students in-depth theoretical knowledge of all sections of recommendations on transfer pricing, as well as skills for using acquired knowledge in practice in the following cases: when forming approaches to pricing in controlling operations, when preparing transfer pricing documentation, as well as when defending one's positions in the process conducting audits by tax authorities or in court.
Завдання: The study of an academic discipline involves the formation and development of students' competencies: integral: INT. The ability to solve complex specialized tasks and problems in the spheres of business, trade, and stock exchange activities or in the learning process, which involves the application of theories and methods of organization and functioning of business, trade, and stock exchange structures and is characterized by the complexity and uncertainty of conditions. special professionals: - Ability to apply transfer pricing methods in commercial and entrepreneurial activities
Learning outcomes: RNS 2.4. Apply appropriate methods of transfer pricing in the commercial activities of enterprises Zn1. Conceptual knowledge acquired in the process of learning and professional activity, including certain knowledge of modern achievements Zn2. Critical understanding of basic theories, principles, methods and concepts in teaching and professional activities Um1. Solving complex unforeseen tasks and problems in specialized areas of professional activity and / or training, which involves the collection and interpretation of information (data), the choice of methods and tools, the use of innovative approaches K1. Communicating information, ideas, problems, solutions and personal experience in the field of professional activity to specialists and non-specialists K2. Ability to effectively formulate a communication strategy AB1. Management of complex actions or projects, responsibility for decision-making in unpredictable conditions. AB3. Ability to further study with a high level of autonomy
Required prior and related subjects: Prerequisites: International trade Co-requisites: International technology transfer, Accounting and information support of commercial activity, Taxation of commercial activity Postrequisites: International transfer operations and contracts
Summary of the subject: The discipline "Transfer pricing" is dedicated to determining the essence, significance, risks, disadvantages and advantages of using transfer pricing by companies operating in the international market. On the basis of real examples, the advantages and disadvantages, risks and threats of the application of transfer pricing are identified.
Опис: Topic 1. The essence of transfer and its scope of application. Price and methods of market pricing. Types of prices. Methods of market pricing. The concept of transfer. Areas of application of the transfer: innovative, (technology transfer), tourist, banking, sports. Transfer and diffusion: the essence and relationship of concepts. Topic 2. The essence of transfer pricing OECD guidelines. The history of transfer pricing. Basic concepts: transfer price, associated persons, controlled transactions. The "outstretched hand" principle. Factors affecting transfer prices. Task of transfer pricing. Topic 3. International and Ukrainian experience in regulation of transfer pricing International experience of transfer pricing regulation. Prerequisites for the introduction of transfer pricing. Legislative basis of transfer pricing in Ukraine. Topic 4. Related persons. Related persons, determination of the percentage of participation and specifics of the relationship of persons without a share in the authorized capital. Signs of connection. Direct and indirect participation. Primary and secondary connection of persons. Topic 5. Criteria for determining controlled operations. Criteria for controlled operations "in essence". Value criteria of controlled operations. Consequences of recognizing the operation as controlled. Fine for documents from the shopping center. Topic 6. Methods of transfer pricing Method of comparative uncontrolled price (similar sales). The resale price method (RPM). Cost plus method (CPM). Net Profit Method (TNMM). Profit sharing method (PSM) Topic 7. Sources of information for tax control of transactions with transfer pricing. Statistical data of state bodies and organizations. Price guides of specialized commercial and online publications. Information programs. Reporting Topic 8. Risks in transfer pricing. Risks of transfer pricing: international experience. International documents on the risks of shopping centers. Financial risks of transfer pricing. Legal risks of transfer pricing. Three-level documentation from the shopping center
Assessment methods and criteria: Assessment of students' knowledge of the academic discipline is carried out on the basis of the results of current control. Current control (100%) is carried out during classes: performance of practical work (25%), performance of control work (12%), oral survey (5%), current testing (8%) and final testing (50%).
Критерії оцінювання результатів навчання: The control work is evaluated at 12 points, of which 10 points are allocated for written performance of the work (independence of execution; correct solution of the task; reliability of results; reasonedness of conclusions) and 2 points - for oral defense of the control work and timely completion. Assessment of practical work is carried out on a 5-point scale (total of 5 works – 25 points), of which 4 points are allocated for written performance of practical work (independence of execution; correctness of the method of solving the task; reliability of results; argumentation of conclusions) and 1 point – for oral protection of practical work and timely execution. The procedure for awarding points for control and practical work in % of the maximum number of points allocated for a certain type of work: 0% – the task was not completed or plagiarism was detected or the fact of non-independent performance of the work was established; 40% – the task is partially completed and contains significant errors of a descriptive, methodical or calculation nature; the conclusions are not reasoned and not concrete; 60% – the task is completely completed, but contains significant errors in answers and calculations; the conclusions contain some shortcomings, the student's judgments are not sufficiently reasoned; 80% – the task is completely completed, but contains some minor shortcomings (dimensions, conclusions, design, etc.); 100% - the task was completed correctly and without comments An oral survey involves obtaining: 5 points – the learner gives correct answers to oral questions, using the appropriate terminology, correctly interprets the main concepts and gives real examples from the subject; 4 points - the student gives answers to oral questions, making minor mistakes. During the answer, he uses the appropriate terms, gives an interpretation of their meaning, but at the same time admits certain inaccuracies.; 3 points - the student cannot give a clear and unambiguous answer to an oral question. He can give the correct answer only with the help of a teacher or other students, makes mistakes in his knowledge of the relevant material, is unable to give an interpretation of basic concepts; 1-2 points - the learner does not know how to answer an oral question or does not answer the essence of the question, demonstrates ignorance of basic concepts and definitions. The current tests are selective tests of the 1st level for each topic provided by the course curriculum. When solving the tests, you need to choose the right answer. Depending on the number of correct answers, the student can receive up to 8 points. Final testing involves solving tests from the entire course. Depending on the number of correct answers, the student can receive up to 50 points.
Порядок та критерії виставляння балів та оцінок: Student learning outcomes are evaluated according to the 100-point evaluation scale established at the University: 100-88 points "Certified with a grade of "excellent" - awarded in the event that the applicant freely and fully masters the program material of the course. The applicant must be able to solve tasks related to practical work. 87-71 points "Certified with a grade of "good" - the applicant admits some errors and inaccuracies that do not affect the overall consistency of knowledge and indicate the applicant's understanding of theoretical, methodical and practical material. 70-50 points "Certified with a rating of "satisfactory" - having a good command of the program material of the course, the applicant does not fully disclose special questions, regularities, does not quite accurately interpret concepts and terms. Applied tasks are generally performed methodically incorrectly, but there are significant discrepancies in the final results. In general, the applicant has minimal knowledge that allows him to perform his professional functions in the future. 49-26 points "Not certified" - the applicant does not have special terminology, does not understand the meanings of specific theoretical, methodical and applied questions. The amount of theoretical knowledge and practical skills of such an acquirer is insufficient for the performance of professional duties. Completed more than 50% of mandatory individual work. 25-0 points "Not certified with the rating "unsatisfactory" - the applicant does not understand the essence of the questions, does not have the basic concepts of the course, completed less than 50% of the required individual work.
Recommended books: Recommended Books: 1. OECD guidelines on transfer pricing for TNCs and tax authorities (June 22, 2010) URL: 2. Hryhorash T. F. Advantages and disadvantages of transfer pricing / T. F. Hryhorash, V. O. Poplavska, D. M. Shutova // Young scientist. – 2016. – No. 1 (28). Part 1. - P. 52-55 3. I. V. Karpenko Organization of transfer pricing accounting at trade enterprises / I. V. Karpenko // Black Sea Economic Studies. - 2018. - Issue 27(2). - P. 125-131. - Access mode: 4. Karpenko, I.V. Methodology of transfer pricing accounting at trade enterprises / I.V. Karpenko // Scientific Bulletin of Uzhhorod University. Series: Economy. - 2018. - Issue 1. - P. 416-424. - Access mode: 5. Kosovska V.V., Kreminets* I.M. Analysis of legislative changes in transfer pricing in Ukraine // Sustainable development – state and prospects: collection of materials of the III International Scientific Symposium (Lviv-Slavske, January 26–29, 2022). – 2022. – C. 194–197. 6. Kosovska V. V., Farat O. V., Kozak* I. I. Study of legislative changes in transfer pricing in Ukraine [Electronic resource] // Economy and society. – 2022. – Issue 44 7. Kruglyak V. Transfer pricing in 2019: new rules and norms. Electronic resource: 8. Onishchenko V. Transfer pricing 2020. Electronic resource: 9. Transfer in entrepreneurship: a study guide / O. V. Farat, V. V. Kosovska, O. E. Shaida. – Lviv: Publishing House of Lviv Polytechnic, 2022. – 300 c. 10. Law of Ukraine dated December 28, 2014 No. 72-VIII "On Amending the Tax Code of Ukraine on Improving Tax Control over Transfer Pricing" 11. Helen Rogers & Lynne Oats. (2022)Transfer pricing: changing views in changing times Educational and methodological support: 1. Electronic discipline "Transfer pricing" in the Virtual learning environment of the Lviv Polytechnic - 2. Transfer pricing: Methodological guidelines for conducting practical classes and independent work for students of specialty 076 "Entrepreneurship, trade and stock exchange activity" / Acc.: V.V. Kosovska - Lviv: Publishing House of Lviv Polytechnic, 2021. - 28 p. Information resources: 1. Pareto Consulting Company 2. Results of DPS work in the direction of transfer pricing. State Tax Service of Ukraine: officer. site URL:
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