Transfer Pricing


The Transfer Pricing Rules were introduced in 2013. The principles of Transfer Pricing Rules are specified in Article 39 of the Tax Code of Ukraine.

The Transfer Pricing application rules are subject to amendments in the course of constant amendments made in the Ukrainian tax legislation.

At present the preparation of the Transfer Pricing reporting is one of the pressing issues for many companies carrying out their foreign economic activities. However, a lack of thorough and profound experience and the increasing demands to the Transfer Pricing Rules on behalf of the controlling authorities significantly increase the business risks.

Those companies which comply with the requirements in the field of transfer pricing shall submit on an annual basis a Report on controlled transactions as well as the analytical documentation package (Analytical Package) at the request of the tax inspection.

At present our service provision in the Transfer Pricing sphere is related with the preparation of reports on controlled transactions in compliance with the current Ukrainian legislation and information disclosed by the Client. 

Our main target is to provide our clients with the qualitative report with the full disclosure of information as follows: related parties, list of controlled transactions with their specification and scope of delivery; choosing and applying the most appropriate transfer pricing method to determine whether the terms of the controlled transaction correspond to the arm’s length principle.

The regular training of our experts in the field of Transfer Pricing analytical package preparation is one of our strategic priorities at present. Therefore, the increase in our scope of services to be rendered in the Transfer Pricing sphere is expected.