Tax authorities all around the world devote more and more resources to monitor international trade and flow of capital in order to collect more taxes via transfer pricing rules. The Ukrainian tax authorities keep pace with the international developments and are getting more experienced in enforcing sophisticated Ukrainian transfer pricing regulations.
Business transactions with (1) related foreign companies, (2) companies from “low-tax” jurisdictions and (3) tax transparent entities may trigger application of Ukrainian transfer pricing rules and relevant compliance obligations. We have a team of professionals managing TP risks of our clients on daily basis.
 Our key transfer pricing services include:

  • Advice on Ukrainian transfer pricing rules and their impact on business transactions

  • “Hot-line” support in arising TP issues

  • Identification of “controlled transactions” that are subject to transfer pricing rules in Ukraine

  • Conducting transfer pricing studies to justify the arm’s length nature of the controlled transactions

  • Preparation of transfer pricing documentation in relation to identified controlled transactions, namely performance of functional analysis, economic analysis and other necessary parts of transfer pricing documentation

  • Assistance in preparation of the report on controlled transactions (TP notification)

  • Education of employees on matters relating to completion of the report on controlled transactions

  • Handling tax authorities’ requests during the whole process of a tax authorities’ TP audit, including supporting in interviews

  • Providing tax and legal support during the transfer pricing dispute resolution

  • Full tax and legal support in the advance pricing agreement (APA) procedure, inter alia preparing necessary documentation to enter into APA procedure, supporting during the negotiation process, etc

Transfer pricing issues are not limited to preparation of documentation, filing the reports, and making tax adjustments (if required), but may also prompt the taxpayer to consider tax planning, seek tax advice, prepare for a tax audit, and challenge the transfer pricing assessments. Upon your request, our professionals will assist you in this broader set of issues as well.


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