In the era of globalization, the expansion of multinational enterprises and the growing volume of international trade have made transfer pricing one of the most critical issues in international business. Transfer pricing refers to the prices applied to transactions of goods and services between related entities or divisions of a company. In practice, the determination of transfer prices is based on the arm’s length principle, supported by several traditional methods such as the Comparable Uncontrolled Price, Cost Plus, Transactional Net Margin, and Profit Split approaches. This article examines the concept of transfer pricing in international trade and analyzes both traditional and modern approaches to its calculation, including the use of artificial intelligence and big data in the digital economy. The findings suggest that modern approaches contribute to increased transparency, reduced information asymmetry, and improved management of tax-related risks in international transactions.

transfer pricing, international trade, arm’s length principle, OECD, IFRS, BEPS, Cost Plus, Profit Split, modern approaches, digital economy.

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