Kreston GCG has a strong record of transfer pricing projects that can help your company minimizing tax risks and turning any tax inspection into a stress-free experience.
21 December 2016 brought us Law No. 1791-VIII "On Amendments to the Tax Code of Ukraine to Improve the Investment Climate in Ukraine". It changed tax regulations pertaining to the arm's length principle that applies to controlled transactions.
Transactions may be deemed as controlled when the following type of transaction is being conducted:
a) transactions with non-residents;
b) transactions involving a sale/purchase of goods (services) via non-resident commission agents;
c) transactions with counterparties from low-tax jurisdictions;
d) transactions with non-residents exempt from income tax (corporate tax) and/or that are not tax residents in their country of incorporation;
e) transactions that use Ukrainian resident companies in the supply chain with non-residents.
Transactions are recognized as controlled if the following conditions are met simultaneously:
1) taxpayer's annual revenue exceeds ₴150 million (after indirect taxes) for the relevant year;
2) size of taxpayer's transactions with each counterparty exceeds ₴10 million (after indirect taxes) for the relevant year.
Transfer pricing reports
The Tax Code of Ukraine stipulates reporting to take the following forms:
1) Report on controlled transactions (to be submitted from October 1, 2017).
2) Transfer pricing documentation (submitted upon a controller's request within 30 calendar days).
Our Tax Department immediately reacts to new amendments and helps international corporations and groups of companies updating and preparing their transfer pricing documents in a time-efficient manner.
Transfer pricing practice by Kreston GCG:
- consultations on general transfer pricing issues;
- preparation of reports on controlled transactions;
- conversion of a report on controlled transactions in MEDoc format so it can be sent straight to the regulator;
- preparation of transfer pricing documents;
- support during inspections;
- appeal against regulators (administrative, judicial);
- forensic and economic analyses and expert studies on transfer pricing matters.