<\/p>\n
The Controlled Transactions Report is filed once a year, by 1 October, and precisely because it is annual the same mistakes come back every time. Some cost a penalty; others leave the report formally filed while a transaction counts as undeclared. Here are the ones we see most often.<\/p>\n
The most expensive of all, because there is no report at all. The reasoning is usually “we have no related parties abroad”. But transactions do not become controlled only through relatedness. The rules also capture transactions with non-residents registered in states on the Cabinet of Ministers list, with non-residents in specific legal forms, and transactions routed through non-resident commission agents.<\/p>\n
The check has to be repeated every year, not done once. The lists of states and legal forms are updated, and a counterparty outside them last year may be inside them this year.<\/p>\n
There are two and they work together: annual revenue above UAH 150 million and volume with a single counterparty above UAH 10 million net of indirect taxes. Companies often look only at the second and conclude the transaction is controlled although revenue falls short. The reverse happens too: revenue is large, so everything with every non-resident gets reported.<\/p>\n
It is a separate document, due on the same date, 1 October. It gets forgotten regularly because “the controlled transactions report” reads as one form. There are two, and a penalty attaches to each separately.<\/p>\n
The controlled transaction amounts have to reconcile with the corporate income tax return and the financial statements. A mismatch is the first thing automated checking sees and it reliably produces a request. Reconcile before filing, not after the request arrives.<\/p>\n
The report carries the transaction code, the country code, counterparty details and the chosen method. An error in a code technically means the transaction was declared incorrectly, which is grounds to treat it as undeclared, with the consequences that follow. Services deserve particular care: they get described so generally that it later becomes hard to show what was actually bought.<\/p>\n
TP documentation is filed on request from the tax authority within 30 calendar days. Building a benchmarking study, an arm’s length range and the reasoning for the method from scratch in that window is not realistic. So the file is assembled in the same season as the report, while the data is at hand.<\/p>\n
Where the group’s consolidated revenue is EUR 50 million or more, a master file is also filed on request, with 90 days allowed. Country-by-country reporting applies to groups from EUR 750 million.<\/p>\n
Correcting the report yourself is better than being corrected after an audit, but it does not always remove liability in full. And separately: paying the penalty does not remove the obligation to file. Paying instead of filing does not work.<\/p>\n
If 1 October has not passed, the order is: check counterparties against the current lists, test both value thresholds, reconcile the amounts with the tax return, prepare the report and the notification, and assemble the documentation in parallel. If the deadline has passed, the sooner you file the smaller the consequences.<\/p>\n
We take this end to end or in stages: transfer pricing<\/a>, or, when only the report itself and a check of the figures is needed, the controlled transactions report<\/a>. Where an audit has already produced an assessment, tax disputes<\/a> take over.<\/p>\n <\/p>","protected":false},"excerpt":{"rendered":" Both value thresholds together, the forgotten group notification, mismatches with the tax return and documentation started after the request.<\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[97],"tags":[],"class_list":["post-4246","post","type-post","status-publish","format-standard","hentry","category-audyt-biznesu"],"aioseo_notices":[],"aioseo_head":"\n\t\t\n\t\n\t\n\t\n\t\n\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\n","aioseo_head_json":{"title":"MK Audit \u0430\u0443\u0434\u0438\u0442","description":"Both value thresholds together, the forgotten group notification, mismatches with the tax return and documentation started after the request. \u0430\u0443\u0434\u0438\u0442","canonical_url":"https:\/\/audit-mk.com.ua\/en\/pomylky-u-zviti-pro-kontrolovani-operatsii\/","robots":"max-image-preview:large","keywords":"","webmasterTools":{"miscellaneous":""},"schema":null,"og:locale":"en_US","og:site_name":"MK Audit","og:type":"article","og:title":"MK Audit \u0430\u0443\u0434\u0438\u0442","og:description":"Both value thresholds together, the forgotten group notification, mismatches with the tax return and documentation started after the request. \u0430\u0443\u0434\u0438\u0442","og:url":"https:\/\/audit-mk.com.ua\/en\/pomylky-u-zviti-pro-kontrolovani-operatsii\/","article:published_time":"2026-09-15T06:04:58+00:00","article:modified_time":"2026-09-15T06:04:58+00:00","og:image":"https:\/\/audit-mk.com.ua\/wp-content\/plugins\/mk-landing\/img\/og-default.jpg","og:image:width":1200,"og:image:height":630,"og:image:secure_url":"https:\/\/audit-mk.com.ua\/wp-content\/plugins\/mk-landing\/img\/og-default.jpg","twitter:card":"summary_large_image","twitter:title":"MK Audit \u0430\u0443\u0434\u0438\u0442","twitter:description":"Both value thresholds together, the forgotten group notification, mismatches with the tax return and documentation started after the request. \u0430\u0443\u0434\u0438\u0442","twitter:image":"https:\/\/audit-mk.com.ua\/wp-content\/plugins\/mk-landing\/img\/og-default.jpg"},"aioseo_meta_data":{"post_id":"4246","title":null,"description":null,"keywords":null,"keyphrases":null,"primary_term":null,"canonical_url":null,"og_title":null,"og_description":null,"og_object_type":"default","og_image_type":"default","og_image_url":null,"og_image_width":null,"og_image_height":null,"og_image_custom_url":null,"og_image_custom_fields":null,"og_video":null,"og_custom_url":null,"og_article_section":null,"og_article_tags":null,"twitter_use_og":false,"twitter_card":"default","twitter_image_type":"default","twitter_image_url":null,"twitter_image_custom_url":null,"twitter_image_custom_fields":null,"twitter_title":null,"twitter_description":null,"schema":{"blockGraphs":[],"customGraphs":[],"default":{"data":{"Article":[],"Course":[],"Dataset":[],"FAQPage":[],"Movie":[],"Person":[],"Product":[],"ProductReview":[],"Car":[],"Recipe":[],"Service":[],"SoftwareApplication":[],"WebPage":[]},"graphName":"BlogPosting","isEnabled":true},"graphs":[]},"schema_type":"default","schema_type_options":null,"pillar_content":false,"robots_default":true,"robots_noindex":false,"robots_noarchive":false,"robots_nosnippet":false,"robots_nofollow":false,"robots_noimageindex":false,"robots_noodp":false,"robots_notranslate":false,"robots_max_snippet":null,"robots_max_videopreview":null,"robots_max_imagepreview":"large","priority":null,"frequency":null,"local_seo":null,"breadcrumb_settings":null,"limit_modified_date":false,"ai":null,"created":"2026-09-15 06:05:37","updated":"2026-09-15 06:55:52","seo_analyzer_scan_date":null,"focus_keyword":null,"additional_keywords":null,"truseo_locale":null},"aioseo_breadcrumb":"