PHENOMENOLOGY OF TRANSFER PRICING: DIALECTICS OF TAXATION OF INVESTMENT REAL ESTATE IN THE GLOBAL CONTEXT

Abstract

Introduction. In the modern globalized economy, transfer pricing has become one of the key instruments of international business, influencing the distribution of profits across jurisdictions and shaping the taxation framework for investment real estate. The relevance of studying this issue is driven by several factors, including the rapid growth of global real estate investments, which complicates financial flows and necessitates effective control mechanisms. Additionally, transfer pricing is often used as a tool for tax burden optimization, sometimes leading to manipulations that undermine fairness and transparency in taxation. Purpose. The study aims to analyze the phenomenology of transfer pricing in the taxation of investment real estate, revealing its socio-economic essence and contradictions in the global context. It seeks to explore the interplay between state taxation policies and investors' interests, particularly in light of international tax standards and regulatory initiatives. Methods. A phenomenological approach is applied to examine transfer pricing as an economic and social phenomenon that emerges at the intersection of state, business, and societal interests. The study also considers dialectical analysis to explore the contradictions between tax revenue maximization by states and cost minimization strategies by investors. Results. The research highlights the dual nature of investment real estate as both an economic asset and a socially significant resource. It reveals the challenges posed by transfer pricing in ensuring tax fairness while maintaining investment attractiveness. Furthermore, the study underscores the growing role of international tax regulations, particularly OECD’s Base Erosion and Profit Shifting (BEPS) initiatives, in promoting transparency and combating tax avoidance. Conclusions. The study confirms the importance of understanding transfer pricing from a phenomenological perspective to develop more effective and fair taxation policies. Given the increasing global emphasis on transparent tax mechanisms, the findings contribute to both theoretical discussions and practical policymaking in the field of investment real estate taxation.