Transfer pricing services in Ukraine | Paper Cloud
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Transfer pricing

Transfer pricing rules in Ukraine require prices in deals with related foreign companies and offshore counterparties to match market prices. They apply when a company’s annual income exceeds UAH 150 million and its transactions with one counterparty exceed UAH 10 million a year.

We identify your controlled transactions and prepare the controlled transactions report and transfer pricing documentation. We work with companies in Kyiv and across Ukraine.

Who it’s for
LLCs
Groups of companies
Foreign-owned companies
Fee
Quoted after we review your transactions

Who is subject to transfer pricing in Ukraine

A transaction becomes controlled when both conditions are met in the reporting year.

ConditionThresholdHow it is counted
Company’s annual incomeover UAH 150 millionFrom all activities, under accounting rules, net of VAT and other indirect taxes
Transactions with one counterpartyover UAH 10 millionSeparately for each counterparty, also net of indirect taxes

Both thresholds are set in Article 39 of the Tax Code of Ukraine. Count all deals with a counterparty for the year, not one contract.

Which transactions are controlled

Not every deal with a foreign company is covered. Five groups are:

Related non-residents

Sales, purchases, loans, services and royalties within your group.

Low-tax jurisdictions

Deals with companies from countries on the Cabinet of Ministers list, even if unrelated.

Special legal forms

Deals with non-residents that pay no corporate income tax, under a separate government list.

Non-resident commission agents

Buying or selling goods and services through a foreign intermediary.

Permanent establishment

Settlements between a non-resident and its permanent establishment in Ukraine.

The government updates these lists from time to time, so we check your counterparties against the current version every year.

Our transfer pricing services

Controlled transactions analysis

We check which counterparties are related or registered in listed countries and test the thresholds.

Controlled transactions report

We prepare the report from your accounting data and file it with the State Tax Service (STS), after reconciling the figures with your books.

Transfer pricing documentation

We describe the group, the functions and risks of each party, choose a method and run a benchmarking analysis.

Advice

We assess a new structure, contract or price change before the deal.

Not sure whether you have controlled transactions? Send us a list of your foreign counterparties using the form at the bottom of the page, and we will tell you where to start.

Report deadlines and penalties

The controlled transactions report is due by October 1 of the following year. Documentation is not filed with the report: the STS can request it, starting from October 1, and you have 30 calendar days to provide it.

ViolationPenalty under Article 120 of the Tax Code
Report not filed300 times the subsistence minimum for an able-bodied person
Documentation not provided on request3% of the transactions, capped at 200 subsistence minimums
Still not filed 30 days after the fine is due5 subsistence minimums for each day
Transactions missing from the report1% of their value, capped at 300 subsistence minimums

The subsistence minimum is taken as of January 1 of the reporting year. Paying the fine does not cancel the duty to file.

How we work

1

We collect data

Counterparties, contracts and annual turnover from your books.

2

We identify controlled transactions

We check the lists and test the thresholds.

3

We prepare the report and documentation

Method, benchmarking and your review.

4

We file the report

By October 1, with documentation ready for an STS request.

What the fee depends on

We quote after reviewing your transactions and agree the fee upfront.

Number of counterparties and transaction types

Report only, or report plus documentation

Complexity of the benchmarking

Time left before October 1

If we keep your books through our bookkeeping services, the data is already with us.

Who handles your transfer pricing

Your transfer pricing is handled by Paper Cloud’s tax consultants, accountants and lawyers, proven over years of practice. The accountant sees actual turnover and source documents, the lawyer reviews contracts with non-residents, and the tax consultant brings it together in the report. Our team communicates in English. Need a contract rewritten for transfer pricing? Our lawyers handle contract analysis and drafting.

Frequently asked questions

What is transfer pricing in simple terms?

It is the state’s control over prices in deals between related companies and with offshore counterparties. The price must match what independent parties would agree on, known as the arm’s length principle. Otherwise, the STS can assess additional corporate income tax on the difference.

Who must file a controlled transactions report in Ukraine?

Corporate income tax payers that had controlled transactions during the year. In practice, these are companies with annual income over UAH 150 million and over UAH 10 million of transactions with one listed non-resident counterparty. Both amounts are counted net of indirect taxes.

What is the difference between the report and the documentation?

The report lists controlled transactions for the year and is filed by October 1. The documentation is a detailed analysis of functions, method and market comparison. It is provided only at the STS’s request within 30 calendar days, but it is wise to prepare it in advance.

Is a deal with an unrelated foreign supplier controlled?

Not always. It becomes controlled if the supplier is registered in a listed country or has a legal form from the special list. The same applies if it acts as a commission agent. We check every counterparty against the current lists each year.

Can the STS audit transfer pricing separately?

Yes. Transfer pricing control is a separate ground for a documentary audit. If one starts, our tax audit support can help. The best defense is documentation prepared before the request, since 30 days is rarely enough for proper benchmarking.

Get your transfer pricing report and documentation

Send a list of your foreign counterparties and annual turnover through the form below. We will identify controlled transactions and quote a fee. A one-off question? Try our accounting and tax consulting.

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