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Transfer pricing
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 is subject to transfer pricing in Ukraine
A transaction becomes controlled when both conditions are met in the reporting year.
| Condition | Threshold | How it is counted |
|---|---|---|
| Company’s annual income | over UAH 150 million | From all activities, under accounting rules, net of VAT and other indirect taxes |
| Transactions with one counterparty | over UAH 10 million | Separately 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.
| Violation | Penalty under Article 120 of the Tax Code |
|---|---|
| Report not filed | 300 times the subsistence minimum for an able-bodied person |
| Documentation not provided on request | 3% of the transactions, capped at 200 subsistence minimums |
| Still not filed 30 days after the fine is due | 5 subsistence minimums for each day |
| Transactions missing from the report | 1% 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
We collect data
Counterparties, contracts and annual turnover from your books.
We identify controlled transactions
We check the lists and test the thresholds.
We prepare the report and documentation
Method, benchmarking and your review.
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
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.
