Transfer pricing in Ukraine: reporting and TP documentation
We identify which of your transactions are controlled, prepare the Controlled Transactions Report and transfer pricing documentation that stands up to a tax authority request. We work ahead of the 1 October deadline and in the 30-day mode when the request has already arrived.
- Screening of transactions against the controlled criteria
- Selection of the TP method and the reasoning behind it
- Benchmarking study and arm’s length range
- Controlled Transactions Report
- TP documentation in the structure required by the Tax Code
- Notification of participation in a multinational group
- Support during a tax authority request or audit
Revenue above UAH 150m and transactions above UAH 10m
A transaction is controlled when the taxpayer’s annual revenue exceeds UAH 150 million and the volume with a single counterparty exceeds UAH 10 million net of indirect taxes. Both conditions have to be met together.
A transaction with an unrelated counterparty can still be controlled
The rules also capture transactions with non-residents from the low-tax jurisdiction list, with non-residents in specific legal forms and transactions routed through non-resident commission agents.
The new rules already apply to the 2025 report
The approach to compiling the list of states and territories was revised, indirect ownership tests for relatedness were clarified, and the required content of the documentation was expanded.
Three deadlines you cannot miss
Filed annually by 1 October of the year following the reporting year. The Notification of participation in a multinational group is due on the same date.
Documentation is filed on request from the tax authority within 30 calendar days. A proper benchmarking study cannot be built from scratch in that window, which is why the file is prepared in advance.
The global documentation is filed on request where the group’s consolidated revenue is EUR 50 million or more. Country-by-country reporting applies to groups from EUR 750 million.
Everything else that touches cross-border transactions
When you only need the report itself and a check of the figures you filed.
When a TP audit has already produced an assessment and a penalty.
To see your tax exposure before the tax authority does.
What clients ask most often
We have no related parties abroad. Does TP still apply?
More often than companies expect. If your counterparty is registered in a state on the Cabinet of Ministers list, or has a legal form from a separate list, the transaction becomes controlled with no relatedness at all.
Can we file the report now and prepare documentation later?
Formally yes: documentation is filed on request. But a request gives only 30 calendar days, and a benchmarking study plus method reasoning is hard to produce in that time. It is safer to prepare the documentation in the same season as the report.
What happens if the report is not filed?
A penalty for the missing report plus a separate penalty for every undeclared transaction, and paying the penalty does not remove the obligation to file. Penalty amounts are pegged to the subsistence minimum and rise every year.
Can you do both the audit and the TP work for one client?
Yes. These are different services and may be combined: preparing TP documentation is not preparing financial statements. If we audit your statements, we agree the scope of the TP work separately so that independence is not affected.
Request a proposal
Tell us the reporting year, what you need and whether a tax authority request has already arrived. We reply within 1 business day.