Identification of the controlled transactions

The companies, which are not sure whether they have controlled transactions and need to prepare reports on transfer pricing, can get help from EBS, we can analyze which transactions refer to the controlled ones free of charge.

In accordance with the Tax Code of Ukraine, the controlled transactions for the income tax payers can be transactions with the following entities:

  • Transactions with the associated non-resident entities, including those performed via formal intermediaries;
  • Foreign economic transactions, relating to еру sale/purchase of goods or services via non-resident agents;
  • Transactions with the non-residents, which are registered in low tax jurisdictions or are tax residents of such jurisdictions;
  • Transactions with the companies of certain legal forms and/or with the companies, which are not tax residents in the countries, where they are registered;
  • Transactions (including in-house settlements) between a non-resident and its permanent representative office in Ukraine.

Transactions with the above mentioned entities can be considered controlled, provided that they meet the following cost criteria (both criteria at the same time):

  • Tax payer’s revenues from any type of activities (excluding indirect taxes) exceeds 150 million hryvnyas;
  • Volume of the transactions with a non-resident, mentioned above, exceeds 10 million hryvnyas.

If you have difficulties determining whether you have any controlled transactions, you can contact us. The EBS professionals can quickly identify all controlled transactions and (if necessary) prepare the documents on the transfer pricing and report on the controlled transactions.

We have been providing the services relating to the transfer pricing since 2013, that is why we have solid experience and a team of experts, who know what they are doing.


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