Transfer pricing in figures
Under Ukrainian legislation, taxpayers engaged in controlled transactions must file reports on controlled transactions (hereinafter “CT”) by October 1 of the year following the report¬ing year. Taxpayers must also compose and keep annual TP documentation. The State Fiscal Service (hereinafter “the SFS”) may request access to such TP documentation during the pro¬cess of a TP audit. Below we have provided infographics outlining the main features of controlled transactions reported during the period 2013–2018 and basic results of TP audits, which were published by the SFS on its official website:
Reported controlled transactions 2013 – 2018
TP audits 2013–2018
In the results from four reporting periods, the SFS established 600 violations of the requirements on reporting deadlines and the completeness of the reports on CT. Therefore, taxpayers were fined EUR 8 million, of which 55% was actually paid to the state budget of Ukraine.
In 2015–2018 the SFS started 58 TP audits, 34 of which have already been completed, resulting in the corporate profit tax assessments presented in the graph here.
430 taxpayers performed self-adjustments of transfer prices and increased their taxable income or reduced losses from controlled transactions in 2013–2016 by a value greater than EUR 443 million.
Download pdf-file of the article (125 Kb)
SIMILAR POSTS
Comparables Selection Was Correct After All, Ukrainian Court Says
Comparables Analysis Insufficient; Ukrainian Court Remands Case
“Massive” requests regarding application of the 30% adjustment on corporate income tax. What is wrong and what to do?
Ukraine: The War is not an excuse to ignore Transfer Pricing Compliance
Finally! Ukraine has joined Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports
New decision of the Supreme Court of Ukraine regarding TP rules: new approaches to the application of the CUP method, but, unfortunately, questions still remain
Ukraine adopts new procedure on advance pricing agreements for transfer pricing purposes
Ukraine Ministry of Finance clarifies general tax consultation on deemed dividends
Ministry of Finance of Ukraine clarifies some TP issues
Ukraine’s new transfer pricing rules expand taxpayer obligations