METHODOLOGICAL ASSESSMENT OF THE ACCOUNTING SUPPORT MODEL FOR CONTROLLED TRANSACTIONS IN THE CONTEXT OF THE ARM’S LENGTH PRINCIPLE

Abstract

Introduction. The organization of analytical and management accounting for controlled transactions is a key component of ensuring compliance with the arm’s length principle. However, the mere existence of internal regulations, accounting registers, or reporting forms does not guarantee that an enterprise’s accounting system is functionally capable of supporting transfer pricing tasks. Therefore, there is a need to develop an integrated approach to assessing the functional development and resource requirements of accounting support for transfer pricing. Purpose. The purpose of the article is to develop a model for accounting support of controlled transactions for transfer pricing purposes and to propose a methodological approach to assessing its functional development and resource labour intensity. Methods. The study applies methods of analysis, synthesis, systematization, comparison, and modelling. The proposed methodological approach is based on a matrix of «functional development – resource labour intensity», which combines criteria for assessing the functional capacity of individual areas of the accounting support system with an evaluation of the resources required for their implementation. Results. A model for developing an enterprise accounting support system for transfer pricing purposes is proposed, covering organizational and managerial, theoretical and methodological, regulatory, accounting and information, technical and functional, control and analytical, and documentation and evidentiary areas. Criteria for assessing the functional development of each area are developed. An approach to determining resource labour intensity is proposed based on the ratio between the labour intensity of a particular area and its baseline labour intensity. The application of the matrix makes it possible to determine the actual state of individual areas, identify elements characterized by insufficient functional development and excessive resource burden, and establish priorities for improving the accounting system. The proposed criteria can also serve as a roadmap for project managers responsible for developing accounting support for transfer pricing. Conclusion. The proposed model and methodological assessment approach provide a practical tool for internal diagnostics and management of the development of an enterprise accounting system for transfer pricing purposes. Their periodic application enables enterprises to monitor changes in functional development and resource labour intensity, adjust managerial decisions, and maintain comparability of assessment results when the criteria or baseline labour intensity indicators change. The implementation of the proposed approach strengthens the evidentiary relationship between contracts, primary documents, accounting records, management reports, and transfer pricing documentation, thereby improving the reliability and effectiveness of accounting support for compliance with the arm’s length principle.