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Практика трансфертного ціноутворення

Home
⁄Services
⁄Transfer pricing practice
  • Analysis of business transactions
  • Developing internal methodology
  • Assistance when signing a contract
  • Preparing TP report
  • Legal support during tax audits
  • Preparing TP documentation
  • In-house training
  • TP policy preparation

Transfer Pricing Practice

In Ukraine Transfer Pricing (TP) rules were introduced on 1 September 2013. Since then, almost every year they have undergone significant changes that need to be taken into account when planning business transactions with foreign counterparties.

Given the high penalties for failure to submit or late submission of the TP Report, or failure to include a controlled transaction to the filed TP Report, failure to submit TP Documentation, we recommend our clients paying particular attention to identification and analysis of the controlled transactions, and their mandatory inclusion in the TP Report, due substantiation in the TP Documentation.

As part of TP consulting, we help our clients to prepare TP policy, especially taking into account particular attention of the tax authorities to TP issues during the tax audits. With a high level of expertise in Transfer Pricing and powerful capacities of the Nexia International network, we offer our Clients qualified assistance in planning, managing, documenting, evaluating and protecting their Transfer Pricing policies and related business processes.

Since 2013, our TP experts have successfully provided consulting services in the field of Transfer Pricing to more than 100 public and private companies, which, in particular, work in the following areas: oil and gas, electricity generation and supply, agriculture, FMCG, food processing, construction, engeneering, IT, pharmacy, etc

РІШЕННЯ
Analysis of business transactions

One of the most important stages in the analysis of the terms of controlled transactions is their correct and exhaustive definition. The timely and correct identification of the controlled transactions allows for effective control over the risks associated with Transfer Pricing.  
 
The purpose of the analysis is to obtain information that gives an objective and accurate picture of the state of business transactions. Our experts analyze business transactions of a group of companies and identify controlled transactions.

 

Developing internal methodology

Development of internal TP methodology includes preparation of the necessary documentation, which involves selecting the most effective and appropriate methodology of Transfer Pricing, definition of pricing policies, preparation of TP template documents, internal control over TP. These services are offered to assist in implementing the TP policy in a company and further monitoring the terms of the controlled transactions.

Assistance when signing a contract

Drawing up and preparing contracts properly will provide and guarantee the security of your business. Our experts will help you analyzing all aspects when signing cross-border contracts for potentially controlled transactions, which will enable the company to avoid additional difficulties in the analysis of such transactions.  Due to many years of experience, our specialists know all the possible nuances and situations that may arise while performing the transactions and which must be properly stipulated in the contract.

Preparing TP report

Preparation of TP report is a rather complicated procedure which involves timely organization and requires professional expertise. Our specialists may provide either professional advice as for the procedure of preparing a TP Report or may prepare the TP Report ourselves and ensure compliance with all applicable tax norms. 

 

Legal support during tax audits

We offer legal support during tax audits which will help to identify and minimize Transfer Pricing risks and in case of administrative or court disputes, facilitate their effective resolution. Our lawyers will help to prevent unintended consequences.

Preparing TP documentation

Our specialists may prepare Transfer Pricing Documentation package in accordance with the requirements of the Tax Code of Ukraine and OECD TP Guidelines, as well as best practices. We guarantee confidentiality and information security to all our clients.

During preparation of the Transfer Pricing Documentation our specialists thoroughly examine the activities of the company within the controlled transactions, investigate relevant markets and fully take into account the specifics of the client’s business.

In-house training

Our Company’s experts offer Transfer Pricing trainings for specialists of a group of companies. In this way, we help companies to reduce the risks associated with Transfer Pricing in the future. 

TP policy preparation

Our specialists can prepare and develop Transfer Pricing policy for a Group of companies. Transfer pricing policies include pricing measures, strategy development and pricing method selection to substantiate the terms of the controlled transactions with the “arm’s length” principle.

Our team

Olena Voznyuk
Olena Voznyuk
Partner
OlenaVoznyuk@nexia.dk.ua
+38 044 233 64 64

Over 15 years of professional experience in fiscal and corporate law, M&A and corporate reorganization, joint ventures and various investment projects, tax and legal audit in different industries, including pharmaceutics, FMCG, agriculture, energy, oil and gas, real estate.  Consulting on national and international taxation, tax structuring, transfer pricing. 
Author and speaker at practical workshop on transfer pricing and international taxation. 

 

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Nexia DK (Nexia DK Audit LLC, Nexia DK Audit and Tax LLC, Nexia DK Audit and Accounting LLC, Nexia DK Audit and Consulting LLC, Nexia DK Legal and Tax LLC, “Nexia DK.Valuation Services” LLC ) is a member firm of the “Nexia International” network. Nexia International Limited does not deliver services in its own name or otherwise. Nexia International Limited and the member firms of the Nexia International network (including those members which trade under a name which includes the word NEXIA) are not part of a worldwide partnership. Nexia International Limited does not accept any responsibility for the commission of any act, or omission to act by, or the liabilities of, any of its members. Each member firm within the Nexia International network is a separate legal entity.

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