Ukrainian transfer pricing proposals present significant implications for taxpayers
A new transfer pricing bill has been registered in the Ukrainian Parliament, which will have a significant impact on taxpayers.
The proposed rules include:
· An advance pricing agreement procedure;
· Eliminating the 20% safe harbour rule;
· Introducing transfer pricing definitions, including “related persons” and “controlled transactions”;
· Clarifying the use of prescribed transfer pricing methods;
· Introducing an audit mechanism within the tax authority; Allowing other parties in a controlled transaction to make an adjustment based on price corrections by the authorities; and
· Introducing reporting requirements and penalties for non-compliance.