Development of glossary in the area of transfer pricing

Introduction. Ensuring transparency and effectiveness of tax control over companies engaged in cross-border activities requires appropriate institutional measures. The unification of the conceptual and categorical apparatus in the field of transfer pricing is a key prerequisite for a consistent understanding of the methodological foundations for counteracting the risks of tax base erosion and profit shifting in the context of harmonization of national tax legislation with international approaches. The purpose is to conduct a scientific examination of the conceptual and categorical apparatus of the OECD Transfer Pricing Guidelines. Methodology: comparative analysis; synthesis and generalization of the data obtained; graphical and tabular methods (to ensure the clarity of the data presentation). Main results and conclusions. The study conducted a comparative analysis of the last three editions (2010, 2017 and 2022) of the OECD Glossary of Guidelines. The study found that the amendments are substantive and editorial in nature. In particular, the main substantive changes are the replacement of the concept of “country” with “jurisdiction” and the replacement of the concept of “shared profits” with “relevant profits”, which is reflected in the 2022 edition of the Glossary. The authors identify that an important aspect of enhancing the perception and simplifying the use of the translation of the OECD Guidelines Glossary (2022 edition) is to determine the order of presentation of terms (according to the alphabet or according to the original document). For the Ukrainian user of information, it is advisable to arrange the terms in the Glossary in alphabetical order.