In Ukraine, the transfer pricing rules were put into effect on 1 September 2013. Since then, almost every year they undergo significant changes that need to be taken into account when planning business transactions = with foreign counterparties.
Given the high penalties for q failure to submit or late submission of the Controlled Transactions Report, or the non-inclusion of a controlled transaction to the already submitted Report, or failure to submit a Transfer Pricing Documentation request, etc., we recommend that our clients pay particular attention to detecting and analyzing controlled transactions and their mandatory inclusion in the Controlled Transactions report and a due justification in the Transfer Pricing Documentation.
In 2020, for the first time, taxpayers with controlled transactions filed a Notice of Participation in an International Group of Companies, and we actively assisted our clients in gathering the information needed to prepare the Notice and compile the Notice itself.
Also, on 23 May 2020, Ukraine introduced a three-level reporting on TP in accordance with Art. 13 of the BEPS Plan. This means that depending on the criteria stipulated by the Tax Code of Ukraine, Ukrainian taxpayers will need to prepare in addition to the usual CT Report and TP Documentation also the Global TP Documentation (Masterfile) and the Country-by-country report .
As part of TP consulting, we help our clients to properly design TP policies, carefully analyze controlled transactions to select the most appropriate TP method and source of information, and test controlled transactions for business purposes. Due to the careful approach of regulatory authorities in conducting TP audits, we personally accompany our customers during such audits and protect their interests in administrative and legal disputes with regulatory authorities.
With a high level of expertise in transfer pricing and powerful capacities of the Nexia International network, we offer to 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 300 public and private companies that, in particular, work in the following areas: oil and gas, electricity generation and electrical supply, growing and sale of various agriculture; defense, food processing, construction, pharmaceutical etc.