Transfer pricing in Ukraine: controlled transactions report and TP documentation
We check which transactions with non-residents fall under control, prepare the Controlled Transactions Report due 1 October and transfer pricing documentation that holds up when the State Tax Service asks for it. We work ahead of the season and within the 30-day window once a request has arrived.
Documentation is prepared in Ukrainian with an English version for the parent company, so the group and the tax authority get the same analysis rather than two separate pieces of work.
- Value thresholds and counterparty lists check
- Functional analysis of the parties
- Choice of TP method with rationale
- Comparables search and arm’s length range
- Controlled Transactions Report and MNE group notification
- TP documentation in the Tax Code format
- Support during a tax request or audit
Short answer
When a transaction with a non-resident becomes controlled and the transfer pricing deadlines
A transaction is controlled when, at the same time, the taxpayer’s annual income exceeds UAH 150 million and transactions with one counterparty exceed UAH 10 million, and the counterparty is a related party, a non-resident from the Cabinet of Ministers’ list of states or legal forms, a non-payer of corporate income tax or a non-resident commission agent. The controlled transactions report and the multinational group notification are filed by 1 October of the following year; transfer pricing documentation within 30 days of a tax authority request, the master file within 90 days. In 2026 the fine for a missing report is UAH 998,400 (300 subsistence minimums) and for missing documentation 3% of the transactions, up to UAH 665,600.
A transaction becomes controlled when two conditions meet
Income above UAH 150m and above UAH 10m with one counterparty
The taxpayer’s annual income under the accounting records exceeds UAH 150m and transactions with one counterparty exceed UAH 10m for the year, net of indirect taxes. Both conditions must be met at once.
Related party status is not required
Controlled transactions include those with related non-residents, with non-residents from states on the Cabinet of Ministers list, with non-residents of specific legal forms, with those who pay no corporate income tax or are not tax residents of their country of registration, and sales through non-resident commission agents.
The lists of states and forms change
A counterparty’s status is tested at the transaction date, so we check each non-resident against the lists in force on that date before adding up volumes. Nothing unnecessary goes into the report and nothing required is left out.
Deadlines you cannot miss
Every year by 1 October of the year following the reporting year, together with the notification of participation in a multinational group.
Documentation is filed within 30 calendar days of a tax authority request. A sound study cannot be built from scratch in that time, so it is prepared together with the report.
The master file is filed on request where the group’s consolidated revenue is EUR 50m or more. Country-by-country reporting applies to groups of EUR 750m or more.
What non-compliance costs
Amounts are tied to the subsistence minimum for an able-bodied person as of 1 January, which is UAH 3,328 in 2026. Paying the penalty does not remove the obligation to file the report or documentation.
UAH 998,400
300 subsistence minimums. If the report is still missing 30 days after the penalty payment deadline, 5 more minimums are added per day, capped at 300.
up to UAH 665,600
3% of the controlled transactions for which documentation was not filed, capped at 200 subsistence minimums.
UAH 3,328 and 6,656 per day
Report: 1 minimum per day of delay, capped at 300. Documentation: 2 minimums per day, capped at 200.
Source: Tax Code paragraphs 120.3 and 120.6 and the State Tax Service guidance on 2026 TP penalties. The amount applied is the one in force on the date of the decision.
Five TP methods and when each one fits
A direct comparison with prices between independent parties. Best for exchange-traded goods such as grain, oil or metal, where quotations exist.
For a distributor that buys from the group and resells without significant processing. The gross margin is compared.
For contract manufacturing and intra-group services. The mark-up on costs is compared.
The most widely used method in Ukraine: the tested party’s profitability is compared with independent companies from databases.
Where both parties make unique contributions and neither can be benchmarked on its own. Used rarely.
If a price falls outside the arm’s length range, the taxpayer can increase its tax liability in the return itself. That costs less than an assessment after an audit.
From the transaction list to documentation
Diagnostics
We take the year’s turnover with non-residents and test the thresholds and each counterparty. You learn whether you have controlled transactions before signing a full engagement.
Analysis and method
Functions, risks and assets of each party, the method and the tested party. This is the part the tax authority later argues with.
Report and documentation
Range calculation, the report by 1 October, documentation in Ukrainian and English. We walk your accountant through every figure.
If a tax request has already arrived, we work within the 30 days and prepare the reply together with the documentation. If there is an assessment, our tax disputes team joins.
What we need for the report and the documentation
The full list comes with the engagement letter. The earlier these are collected, the calmer September gets.
The year’s turnover with non-residents by counterparty, with goods or services and their codes.
Contracts with non-residents and annexes, invoices, acts, customs declarations, delivery and payment terms.
Ownership and control chart, parent company details and group consolidated revenue.
Cost calculations, price lists, internal pricing policies, discounts and credit terms for related parties.
Annual financial statements and trial balance, data to test the value thresholds.
Earlier reports and TP documentation, correspondence with the tax authority on these transactions.
Other cross-border tax work
When you only need the report or a check of what was filed.
To see tax risks before the tax authority does.
All consulting services on one page.
What clients ask most often
We have no related parties abroad. Does transfer pricing still apply?
More often than people expect. If the counterparty is registered in a state on the Cabinet of Ministers list, has a legal form from the separate list or pays no corporate income tax, the transaction is controlled without any related-party link once the value thresholds are met.
What does transfer pricing documentation include?
A description of the group and the controlled transactions, functional analysis, the choice of TP method, a comparables search, the arm’s length range, a conclusion on whether prices meet the arm’s length principle, and calculation appendices. In Ukrainian, with English for the group if needed.
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 failure to file costs 3% of the transactions. It is wiser to prepare it in the same season as the report.
What happens if the report is not filed?
A penalty of 300 subsistence minimums, UAH 998,400 in 2026, then 5 more minimums a day if the report is still not filed. Paying does not remove the obligation to file.
When is advice enough and when is documentation needed?
Advice is enough when you need to know whether a transaction is controlled, how to structure a contract with a related party or what the price should be. Documentation is required once controlled transactions exist.
What is a transfer pricing self-adjustment?
If the calculation shows the price is outside the arm’s length range, the taxpayer can increase taxable profit in its corporate income tax return. This settles the issue before an audit and costs less than an assessment with a penalty.
Do you provide both audit and transfer pricing to one client?
They are different services: TP documentation is not preparation of financial statements. If we review your statements, the TP scope is agreed separately to protect independence.
Get a proposal
Tell us which year you need the report or documentation for and whether a tax request has already arrived. We reply within one business day.