Assessment of the effectiveness of tax control of transfer pricing in Ukraine in the context of digital transformation

Abstract

Abstract: The relevance of the study is due to the fact that insufficient digitization and integration of information systems, as well as the low level of digital competence of regulatory authorities, create risks of erosion of the tax base, tax disputes, and a decrease in the confidence of transnational corporations in tax regulation. In such conditions, the development of innovative approaches to assessing the effectiveness of tax control over transfer pricing becomes particularly important. The purpose of the study is to identify problematic aspects of the functioning of the transfer pricing tax control system in the context of digital transformation and to assess their impact on tax transparency and budget revenues. Methods. The article uses systematic and comparative analysis, examines foreign experience in tax control in EU and OECD countries, and conducts a functional analysis of the effectiveness of transfer pricing tax control based on data from the State Tax Service of Ukraine for 2013–2025. The results of the study showed that the low level of digitalization of tax control complicates the monitoring of controlled transactions, increases the duration of audits, and reduces the effectiveness of administration. An analysis of international practice demonstrates the effectiveness of implementing unified digital platforms, Big Data algorithms and artificial intelligence, risk analysis panels, and automated information exchange (CbCR, CRS). It was concluded that tax control of transfer pricing in Ukraine is in a transitional stage of digital technology implementation. The proposed measures will contribute to the creation of a transparent, modern, and sustainable tax administration system that meets international standards and supports the development of the national economy.