Transfer pricing in Ukraine: reporting and TP documentation<\/h1>\n
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.<\/p>\n
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- Screening of transactions against the controlled criteria<\/li>\n
- Selection of the TP method and the reasoning behind it<\/li>\n
- Benchmarking study and arm’s length range<\/li>\n
- Controlled Transactions Report<\/li>\n
- TP documentation in the structure required by the Tax Code<\/li>\n
- Notification of participation in a multinational group<\/li>\n
- Support during a tax authority request or audit<\/li>\n<\/ul>\n<\/div>\nTimeline<\/span>from 3 weeks<\/strong><\/div>\nFee<\/span>quoted per engagement<\/strong><\/div>\n<\/div><\/div>\n<\/section>\n
\n \n\nBoth thresholds at once<\/div>\nRevenue above UAH 150m and transactions above UAH 10m<\/b><\/p>\n
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.<\/p>\n<\/div>\n
\nNot only related parties<\/div>\nA transaction with an unrelated counterparty can still be controlled<\/b><\/p>\n
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.<\/p>\n<\/div>\n
\nWhat changed<\/div>\nThe new rules already apply to the 2025 report<\/b><\/p>\n
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.<\/p>\n<\/div>\n<\/div>\n
\n\nThe TP calendar<\/div>\nThree deadlines you cannot miss<\/h2>\n<\/div>\n
\n01.10<\/b>Controlled Transactions Report<\/strong><\/p>\nFiled 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.<\/p>\n<\/div>\n
30<\/b>Days for the TP documentation<\/strong><\/p>\nDocumentation 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.<\/p>\n<\/div>\n
90<\/b>Days for the master file<\/strong><\/p>\nThe 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.<\/p>\n<\/div>\n<\/div><\/div>\n
\nRelated services<\/div>\nEverything else that touches cross-border transactions<\/h2>\n<\/div>\n