When transfer pricing risks are identified, the challenge for the tax authorities is to maximize results while ensuring that businesses and other stakeholders maintain confidence in the tax system. The issue of control over transfer pricing requires a comprehensive settlement, requires in-depth analysis and taking into account the recommendations of a group of experts in order to bring legislation and reporting on transfer pricing to OECD standards, which will improve the overall efficiency of transfer pricing regulation in Ukraine by improving monitoring of the activities of taxpayers, administrative and control procedures, increasing the competence of employees, the quality of tax audits. The purpose of the article is to determine the key factors for the effective functioning of transfer pricing counteraction mechanisms and the directions of their development. It is shown that transfer pricing schemes are carried out using various techniques of aggressive tax planning, which, accordingly, requires the introduction of additional countermeasures.