Preparation of Transfer Pricing Documentation Package

Who needs the Transfer Pricing Documentation Package service?

Transfer pricing rules in Ukraine apply to a transaction if:

- The company’s total income exceeds 150 million UAH;
- The total amount of all transactions with a counterparty exceeds 10 million UAH;
- The counterparty is not a resident of Ukraine and:
  — is either a related party;
  — or a tax resident of a country on the list of low-tax jurisdictions, or its legal form is listed among specified legal forms (e.g., LLP in the United Kingdom);
  — or other cases apply.

 

Purpose of transfer pricing:

To establish prices that would align with criteria applicable between independent parties under similar conditions.

The service process includes:

- Identification of controlled transactions;
- Risk identification (conducting analysis);
- Analysis of transfer pricing policies and intragroup contracts;
- Functional and value chain analysis;
- Profit determination and cost allocation;
- Review and comparative analysis of current foreign economic activities (FEA);
- Consulting on contract drafting with tax risk considerations;
- Support during tax audits;
- Representation of the company’s interests in court against counterparties or third parties;
- Assistance in preparing Advance Pricing Agreements.