The economic essence of transfer pricing and theoretical-methodological foundations of its formation

Authors

Keywords:

transfer pricing, arm's length principle, related parties, multinational corporation, tax base, comparable transaction, profit allocation, BEPS

Abstract

The article examines the economic essence of transfer pricing, the patterns of its formation, and the theoretical foundations of the arm's length principle. The author provides a comparative analysis of five internationally recognized methods for determining transfer prices and evaluates the possibilities of their application under the conditions of the Uzbek economy. The research findings demonstrate that, due to the lack of comparable data in Uzbekistan, the Transactional Net Margin Method (TNMM) remains the most widely used method. In the final part of the article, proposals and recommendations aimed at improving the methodological framework for transfer pricing are developed.

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Published

2026-08-28

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