Transfer Pricing
Manage Transfer Pricing Without Stress. In today’s global trade environment, Ukrainian businesses need solutions that not only meet compliance standards but also support growth.
Introduction
Transfer Pricing Services in Ukraine
As Ukraine’s economic ties across borders grow, transfer pricing has become a pivotal concern for any business engaged in foreign economic transactions.
At Moore, we deliver more than compliance. We offer transfer pricing solutions that protect value, manage risk, and support your global ambitions with confidence and precision.
- Identification and classification of controlled transactions
- Preparation and filing of Reports on Controlled Transactions and Notifications of participation in international groups
- Development of comprehensive TP documentation: Local Files, Master Files, and Country-by-Country Reports
- Functional and value-chain analyses (FAR analyses)
- Selection and justification of appropriate TP methodologies (e.g., CUP, Cost-Plus, TNMM, Profit Split)
- Designing and documenting intercompany agreements and pricing policies
- Support for Advance Pricing Agreements (APAs) and pre-clearance coordination
- Defense and support during TP audits, including legal and economic justification, objection drafting, and dispute resolution
- Strategic advisory for future-proof TP policies and training for finance and legal teams
TAX Services
Why Moore
We are more than traditional accountants, we support businesses, public organizations and investors as trusted advisors and strategic partners.
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Local expertise in a global framework
Since its introduction via Article 39 of Ukraine’s Tax Code, transfer pricing rules have become increasingly complex. Many local firms lack deep experience and face meaningfully higher operational risks. Our specialists, however, bring both strong local understanding and access to Moore Global’s international transfer pricing network, enabling cross-border consistency and best-practice alignment.
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Tailored, commercially driven strategies
We craft bespoke transfer pricing solutions, from documentation and analytical packages to risk assessments, all grounded in the economic realities of your business.
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Proactive risk management and audit readiness
With escalating audit activity and legislation changes, especially under martial law where deadlines are suspended but oversight resumes post-regulatory pause — proactive planning is essential. We help you anticipate and mitigate exposures, ensuring compliant readiness for audits and phased actions.
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Full-spectrum support backed by global know-how
Our services extend across the full transfer pricing lifecycle: from identifying controlled transactions and preparing analytical documentation, to defending pricing policies under audit and advising on APAs. Moore’s global network offers expertise and coordination vital to multinational operations.
Benefits
Value of working with us
We ensure your transfer pricing practices and reporting meet Ukrainian law and align with OECD principles. This includes documentation such as Local Files, Notifications, Master Files, and Country-by-Country Reports.
Our documentation, economic justification, and consistent policies stand strong under scrutiny, reducing risks of penalties and profit adjustments.
Through functional and value-chain analyses, we ensure your intra-group pricing reflects actual business activities strengthening your TP position.
We help optimize intercompany agreements for services, financing, licensing, intangibles aligning them with arm’s-length standards.
With consultations grounded in local regulations and global standards, you maintain oversight while focusing on growth.
Looking for clear, reliable tax advisory support?
Get in touch with our Tax Services team to navigate compliance, manage tax risks, and make informed decisions with confidence.
- Contact Us
- Proposal Request
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