Transfer Pricing

Multinational enterprises have been major actors of the global economy for a long time. One of the main advantages of international business structures is the possibility to minimize or to completely avoid taxation in different jurisdictions. In many cases this fact may become the basis for unfair payment of taxes – not in those jurisdictions, where a multinational enterprise actually gets its profits, but in those, where the tax rate is lower. The solution of this problem lies in the scope of transfer pricing rules, helping tax authorities to control payment of taxes by multinationals. EBS offers a wide variety of services, that may assist business both to assess its transfer pricing risks and weaknesses and to prepare all the necessary documents in order to provide them to the State Fiscal Service of Ukraine for the purpose of execution its controlling function over international transactions.
Detection of controlled transactions
For those companies who are not sure if they have controlled transactions and whether they should compile transfer pricing reports, EBS may help and analyze which operations actually fall under the definition of the controlled ones for free.
Advice on transfer pricing issues
The extensive expertise and experience of EBS specialists allows us to offer advice on any transfer pricing issue - from advice on reporting on controlled transactions to business structuring or the preparation of international reporting within the framework of CbCReporting.
Preparation of reports on controlled operations
Transfer pricing reports should be submitted annually to the supervisory authority to provide information on controlled transactions, which were carried out by the taxpayer during the reporting year.
Preparation of international reports for CbC Reporting
EBS is willing to assist businesses that have to provide their parent companies with information for the purpose of international transfer pricing reporting with the compilation of reports and / or consulting on transfer pricing matters.
Preparation of transfer pricing documentation
EBS experts will conduct a comprehensive analysis of the controlled transactions, establish whether the profit has been shifted to other jurisdictions and company has avoided taxes in Ukraine, and prepare high-quality documentation that will protect the business from claims of the State Fiscal Service.
Carrying out of benchmarking study
For the companies which prepare transfer pricing documents in-house or which want to understand the level of profitability that is marketable for their industry before conducting controlled transactions, EBS is here to offer you benchmarking study as an independent service (usually benchmarking is the part of the transfer pricing documentation).
Audit of transfer pricing documentation
For those companies which prepare the transfer pricing documentation on their own, EBS can offer a service to examine and verify the correctness of the transfer pricing documentation. According to the results of this audit, taxpayers receive advice on what should be changed or supplemented in the documentation in order to comply with the requirements of Ukrainian legislation.
Accompanying the procedures of Advance Pricing Agreement
EBS will help to prepare a complete package of documents for the Advance Pricing Agreement with the State Fiscal Service of Ukraine, and will also participate in negotiations on the APA with the authorities.
Development of intragroup transfer pricing policy
For multinational companies that require intragroup standards for pricing in transactions between group members in order for the transactions to comply with the arm’s length principle, EBS is ready to offer a service of the development and implementation of intragroup transfer pricing policy.

Practice experts

Alina Bakulina

Partner, Head of TP group
Alina has a vast experience in the area of transfer pricing, companies restructuring and international consultancy.
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Sorry, this entry is only available in Ukrainian.
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