Transfer Pricing Control Services

According to the Tax Code and a number of other laws adopted in 2019-2021, enterprises whose annual income exceeds UAH 150 million and the volume of business transactions exceeds UAH 10 million with non-resident counterparties, and at the same time at least one of the criteria listed below is met:

  • related parties;
  • operations through non-resident brokers;
  • non-resident from a low-tax jurisdiction from the list of the Cabinet of Ministers of Ukraine;
  • non-resident with a legal form according to the list of Cabinet of Ministers of Ukraine;
  • operation between a non-resident and a permanent establishment in Ukraine,

must draw up the Report on Controlled Operations based on the results of such a year and submit it to the State Tax Service of Ukraine by October 1 of the year that follows the reporting one. At the same time, starting from 2021, together with the Report on Controlled Transactions, the taxpayer who carried out controlled transactions, must submit the Notice of Participation in the International Group of Companies before October 1 of the next reporting year.

The norms of the current tax legislation of Ukraine provide for significant penalties for non-compliance/untimely compliance with the requirements of such legislation, the amount of which can reach up to 300 tax-free minimum incomes of citizens.

K.A.C. Group experts offer professional preparation of the Report on Controlled Operations, its annexes (information about a person participating in controlled operations, information about controlled transactions, information about related parties) and a package of relevant documentation in accordance with the requirements of the Tax Code of Ukraine, and preparation of special Notifications.

K.A.C. Group also offers:

  • Consulting and explanatory work with company employees in order to pre-empt the inclusion of business operations under the control of transfer pricing;
  • Adjustment of the previously submitted report, its defense in court;
  • Auditor’s opinion on the absence of the need to prepare and submit the report.
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