Налоговые услуги карточка

A well-designed tax strategy is a strong
competitive advantage capable of raising capital
and ensuring long-term financial stability

Do you want to get our legislation reviews?


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.

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.

Size criterion
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.


The Tax Department of Kreston GCG recommends running agreed-upon procedures to verify the accuracy of tax accounting and tax reporting. With this service, you as an owner or your management will have timely knowledge of the tax risks within business activities. Auditor's recommendations can help you eliminate the discrepancies (violations) in the tax accounting and minimize penalty charges.

Kreston GCG recommends running comprehensive tax audit and tax reviews. Mind that tax reviews are selective and pertain to specific taxes (fees) and/or business transactions.

A tax audit (review) can pertain to:
- Corporate income tax;
- Value-added tax (VAT);
- Personal income tax;
- Environmental tax;
- Rental payments;
- Property tax;
- Single tax (a tax under simplified taxation);
- Withholding tax;
- Controlled transactions (transfer pricing): identification and analysis;
- Permanent establishment of a non-resident.

When conducting a tax audit (review), our auditors analyze and examine source documents, accounting ledgers, tax returns, and financial statements. Through a comprehensive review and analysis of the input information we examine transactions from all angles, establish if they were recorded in the statements properly and assess their compliance with the current tax or other legislation.

We engage only high-profile experts, auditors, accounting professionals, and tax lawyers.


The right to administrative appeal against decisions of regulatory authorities is essential when it comes down to pre-trial dispute settlements. Resolving such disputes under an administrative appeal can save you time and effort without resorting to a judicial appeal.

The current state of affairs shows that tax inspectors misapply the tax law and do not pay due attention to audit findings, which results in additional illegal tax charges and financial sanctions.

Taking an administrative appeal against assessment notices and decisions of fiscal services is one of the best ways to settle conflicts and defend your rights.

Administrative appeal is a legally established procedure to protect rights and legitimate interest of legal entities violated by a decision, action, or inaction of the fiscal service. An administrative appeal takes the form of a written complaint and binds a regulator to react and respond to the merits within a specific timeframe.

Once an administrative appeal is lodged, a taxpayer can initiate a forensic analysis. From there, a forensic expert provides an informed and objective written conclusion on the matters. The audit findings requested by the taxpayer will contest the regulator's decision and enter into the case file. Such findings, if the accounting expert approves of taxpayer's actions, will provide proper assurance as to the business activities and tax accounting and cast doubt on the findings of the tax authority.

Andrii Popov

Andrey Popov


Transfer Pricing
Tax Audit
Tax Dispute Resolution

Andrii Popov
Andrey Domrachev

Andrey Domrachev

Managing Partner

Transfer Pricing
Tax Planning and Structuring

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