Development of information and search tools in the context of implementation of OECD recommendations in the area of transfer pricing

The OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022 (hereinafter referred to as “OECD Guidelines”) are the main document for regulating transactions between related parties within MNCs and ensuring fair allocation of tax liabilities between jurisdictions. The large scope of this document, its complex structure and references to interrelated rules and practices complicate access to the necessary information both by the controlling authorities and taxpayers, which necessitates the search for ways to improve the information and search tools in the context of harmonization of domestic legislation with international taxation rules. The purpose is to ensure accessibility and increase the efficiency of the use of the OECD Guidelines by improving the information and search tools (development of a Subject Index with cross-references to the provisions of the current tax legislation of Ukraine). Methodology: analysis (to study the OECD Guidelines); comparative analysis (to identify differences and correspondences in the provisions of the OECD Guidelines and the current tax legislation of Ukraine); systematic approach (when developing the Subject Index according to the OECD Guidelines Glossary in the version of 2022); tabular method (for summarizing data). Main results and conclusions. The article identifies a number of terms that do not have an appropriate legislative definition in the regulatory and legal framework of Ukraine in the field of taxation The results confirm the expediency of continuing research in the field of harmonization of international and national tax legislation, development of new information retrieval tools and improvement of the translation of key international documents. The conclusions formulated in the article demonstrate the importance and relevance of improving information retrieval tools for the use of the OECD Guidelines in Ukraine, ensuring more effective application of the transfer pricing principles in the international and national contexts.