Теоретичні та прикладні питання економіки. Збірник наукових праць.

Випуск 2 (51)

UDC 336.225

JEL H25, M41, C55

ORCID ID: 0009-0006-9261-4553

Research ID: KCX-9069-2024

DOI https://doi.org/10.17721/tppe.2025.51.18

Ihor Prytula, phd student,

Taras Shevchenko Kyiv National University, Kyiv

igor_pritula@knu.ua

STRATEGIC APPROACHES TO THE IMPLEMENTATION OF DIGITAL SOLUTIONS IN TRANSFER PRICING

The article provides a comprehensive analysis of approaches to implementing digital solutions in the field of transfer pricing (TP), with a particular emphasis on the transformation of the benchmarking process-one of the most labor-intensive and strategically important stages of TP documentation. The study traces the evolution of digital technologies: from the initial phase of technical automation, which included webpage screenshot generation, data capture, and basic web-processing tools, to advanced intelligent platforms capable of autonomously identifying potential comparable companies, analysing their web content, and classifying business activities. The article demonstrates how automated data-extraction algorithms, NLP classifiers, and LLM-based analytical models create a qualitatively new level of analysis by significantly reducing manual operations and improving the reproducibility and accuracy of benchmarking results.

The study substantiates that digitalisation acts as a key driver of transparency, manageability, and scalability of TP processes. Based on real cases from 2020-2025, it is shown that the use of artificial intelligence tools reduces labour costs for benchmarking by 3-6 times, decreases erroneous inclusions by more than 90%, substantially lowers the risk of regulatory adjustments, and enables the standardisation of benchmarking procedures across different jurisdictions and analytical teams. The proposed systematic approach includes three core transformation levels: building algorithmic models, developing a new “human-AI-human” process logic, and integrating digital modules into corporate information systems.

The findings indicate that digitalisation is no longer merely an instrument of operational optimisation but is becoming a strategic component of tax compliance. It forms a foundation for implementing intelligent, reproducible, and transparent approaches in TP, enhancing companies’ resilience to regulatory risks, strengthening methodological consistency, and improving competitiveness in a global environment.

Keywords: transfer pricing, benchmarking, digitalization, automation, artificial intelligence, comparable companies, financial analytics.

Full Text: PDF

DOI: https://doi.org/10.17721/tppe.2025.51.18