Transfer pricing risks assessment within application of factor analysis

Implementation and adaptation of the risk assessment system defined by the OECD into national legislation will provide guidance for both the tax authorities and taxpayers. It will reduce the resource costs in the process transfer pricing risk identification and analysis as well as increase the effectiveness of transfer pricing inspections. The article presents the fundamentals of transfer pricing risk analysis and assessment, based on international practice. A technique for evaluation of the indicators significantly impacting the assessment of transfer pricing risks (profitability, operation structure) has been defined. To improve the process of arranging transfer pricing risk analysis, a proposed matrix of transfer pricing risk indicators can be used. For application consistency purposes, the main typical indicators of transfer pricing risks have been systematized into a matrix, in which the accounting and financial reporting indicators are given accordantly with each factor.