Transfer pricing as a means of minimizing tax manipulation in operations with non-residents

The article examines current trends in transfer pricing as a means of minimizing tax manipulation, including operations with non-residents. The concept of transfer pricing and controlled transactions, the criteria that indicate that the transaction is under control, including operations with non-residents has been disclosed. The methods of establishing compliance with the conditions of the controlled operation of the «outstretched arm» principle and the basis for their application, as well as penalties in the field of transfer pricing have been analyzed. The international and domestic regulatory framework for transfer pricing has been considered, the features of globalization of tax legislation in this matter have been identified. Features of the subjectivity of national legislation in the field of transport pricing have been highlighted and ways to minimize the risk of enhanced monitoring by regulatory authorities have been presented. The changes that have taken place in transfer pricing since the beginning of the COVID-19 pandemic have been disclosed.