TRANSFER PRICING IN THE AGRO-INDUSTRIAL COMPLEX: SECTORAL SPECIFICS AND TAX REGULATION RISKS

Introduction. This policy of the enterprises of the agro-industrial complex is an instrument for the implementation of strategic and tactical requirements aimed at expanding supplies and increasing the competitiveness of production. One of the important aspects of this policy is transfer pricing, which transfers the formation of goods and services within the framework of state structures of one enterprise or group of enterprises. In the context of the agro-industrial complex, where vertically integrated companies are actively operating, the problem of transfer pricing becomes particularly relevant, since incorrect pricing can lead to distortion of financial results, distortion of the real profitability of individual units, and a decrease in the efficiency of overall management. The purpose of the article is to identify and scientifically substantiate the features of price formation for agricultural products, taking into account industry specifics, the influence of the external environment, and the need to minimize transfer pricing risks in the field of agricultural production. Results. The article examines the specific features of transfer pricing in the agro-industrial complex (AIC) as one of the most risk-prone areas in the field of tax regulation. It is noted that the agricultural sector possesses a number of unique characteristics that complicate the application of standard transfer pricing approaches. These include uneven land fertility, production seasonality, the absence of stable exchange markets for a significant portion of agricultural products, and complex corporate structures of agro-holdings. The systematizes key transfer pricing risks arising from controlled transactions within the AIC. The identified risk categories include: resource asymmetry, the use of simplified tax regimes, limited transparency in barter transactions, and challenges in determining comparable market prices. The emphasizes the need to adapt tax monitoring methodologies to the sector’s specificities, particularly considering the economic role of land as a source of natural rent. Conclusions. The proposes the use of an expanded set of risk indicators, integrated with financial ratios and production parameters, as a means to enhance the effectiveness of fiscal oversight. The implementation of guaranteed purchase prices is considered a potentially effective instrument for stabilizing government pricing policy. The findings of the study may be used to improve the transfer pricing policy in Ukraine’s agricultural sector, increase tax transparency, and prevent artificial profit shifting to low-tax jurisdictions.