+ Word must be in search result. - Words must not be in search result. * Word start/end on characters before/after symbol. ""Words in quotes will be searched as phrase.


The Law of Ukraine “On Amendments to the Tax Code of Ukraine on Transfer Pricing”

09 August, 2013 Documents of the state authorities

We bring to your attention the final text of the Law of Ukraine “On Amendments to the Tax Code of Ukraine on Transfer Pricing” for comparison with earlier versions. The final text of the Law was signed by the President of Ukraine on July 31, 2013 and published on the official website of the Verkhovna Rada of Ukraine.

It is worth mentioning that at the first perfunctory reading of the text you may find some deviations from the version adopted by the Verkhovna Rada of Ukraine on July 4, 2013.

For instance, definition of persons considered to be related for the purposes of transfer pricing (subpara. 14.1.159) was extended with the following interpretation:

“c) legal entities – if the same person directly and/ or indirectly owns corporate rights of such legal entities and the size of the share of corporate rights in each entity constitutes 20 percent or more”.

In subpara. to pricing methods, in case of application of which the choice of the party of a controlled operation is to be accomplished, was added method “ resale price” and deleted “ income distribution”.

Similar changes in the pricing methods occurred in the subpara.

In determining the final provisions (Chapter II of the Law) under Amendment 446 of deputy Khomutynnik V. (regarding the date of Law entering into force) the para. 1 was extended with the provision that para. 2 and 3 of this section shall enter into force from the day following the day of publication of the Law.

Download pdf-file of the final text of the Law on transfer pricing as of July 31, 2013 in Ukrainian (259,0 Kb)

Download pdf-file of the Draft Law on transfer pricing of as of July 4, 2013 in Ukrainian (221,0 Kb)

Views 4259


Global Trend: Operations with Raw Materials and Traditional Hard Industrial Products as a target of TP 20 November, 2018    526

Parallel Import: Hidden Tax Risks for Official Importers in the context of Transfer Pricing rules 24 October, 2018    1472

The spirit of the international community of TP professionals

Impressions of participation in the Global Transfer Pricing Forum in Munich under the auspices of the International Tax Review
17 October, 2018    1036

WTS Global Country TP Guide:
A comprehensive survey on Transfer Pricing from 73 countries
12 October, 2018    1272

Bulgaria is excluded from the list of “low tax” jurisdictions for TP purposes 27 April, 2018    2863

Transfer Pricing penalties: is it OK to apply penalty for the late submission of the report on controlled transactions for the period before January 01, 2017? 26 April, 2018    609

Transfer pricing penalties: general overview 12 March, 2018    34176

The list of “low-tax” jurisdictions, adopted by the Cabinet of Ministers of Ukraine for transfer pricing purposes, was amended 07 March, 2018    4054

TP disputes: what we can understand from the first dispute in Ukraine that concerns application of the net margin method 23 February, 2018    910

Special rules concerning the permanent establishment of non-residents in TP changes from January 01, 2018. What to prepare for? 06 February, 2018    1483

30 % adjustment under subpara. 140.5.4 of the Tax Code of Ukraine from now on will cover one more kind of transactions. What do we think about practical application of new rules? 22 January, 2018    1457

The list of legal forms of non-residents who do not pay income tax (corporate tax), including tax on income received outside the state of such non-residents’ registration, and /or are not tax residents of the state in which they are registered as legal entities 22 January, 2018    5821