The ways of feedback

You can contact us through this form or EASY CONTACT - at the bottom of the page by clicking on the icon convenient for you method. ⇓

compare_arrows0

Transfer pricing

Refine Search

Transfer pricing

Transfer pricing ("Transfer Pricing", "TP", abbreviated "TP") in the classical sense is called the sale of goods, works and services within the holding company between related parties at prices that can potentially differ from prices taken at the market.

In Ukraine there are special rules for the verification of transfer prices for tax purposes. Today it is one of the most complex and controversial institutions of the Russian tax law requiring separate tax accounting, reporting and monitoring risks.


Our advantages

We understand the complexity and the high cost of these projects for our clients and respect their right to effectively spend their funds. Unlike many, we strive to be efficient and economical for our customers. We have a flexible approach to the organization of work in this direction: we can take the whole complex of actions on transfer pricing in the company and to prepare guidelines for staff about the actions in a particular case. In many cases the second option is much more efficient and beneficial to the client: at the end of the project You spend less money on our services, and Your staff gains invaluable experience with transfer pricing, which You can use in the future. Believe me, it pays!

The transfer pricing services (controlled transactions between related parties). Identification of risks of transfer pricing, determination of market prices, support in tax audits and notices of controlled transactions.


A brief algorithm of determining the status of a controlled transaction looks like this:

– criterion 1: if the sum of the income of the taxpayer for the year does not exceed UAH 50 million. – the operation will not be controlled;

– criterion 2: if the volume of transactions with non-residents does not exceed UAH 5 million. – the operation is not controlled;

– criterion 3: if the counterparty does not meet any of the sub-criteria, namely the sub-criterion "A" the counterparty from low-tax jurisdiction; the sub-criterion "B" – contractor-non-resident and a connected person; the sub-criterion "B" of foreign trade transactions through non-resident agents; sub-criterion "G" – the foreign trade operations through the "strip" surgery is not controlled.


Tax control in the sphere of transfer pricing is carried out by monitoring controlled operations or conducting audits of taxpayers.

Monitoring is carried out by:

surveillance over the prices and terms of transactions carried out by comparing the level of prices and terms of controlled transactions to detect price deviations;

– analysis of reports on controlled transactions;

– analysis of documentation.

In the analysis report, the inspectors take account of the results of operations of the company. In this case, the indicators of recognition of risks, in particular, are:

– the loss ratio for the previous 3 years;

– industry-average profitability;

– conducting business transactions, atypical for the current activities of the payer.

Tax code of Ukraine obliges every taxpayer regardless of the type and nature of its activities:

  • to independently control the presence of the so-called "controlled transactions" that fall under transfer pricing rules;
  • independently inform specially authorized tax authority on such transactions.
  • prepare the necessary documentation and to justify the price in controlled transactions;
  • to pass a tax audit in respect of such transactions, if it is initiated.

It's a tough job, requiring the taxpayer to additional resources, knowledge and skills. Meanwhile, the penalties for violating the rules of transfer pricing are currently the largest in the tax law.

To understand all the intricacies of transfer pricing, to avoid making mistakes, to build a methodology of market prices will help our specialists.


The transfer pricing services (controlled transactions between related parties). Identification of risks of transfer pricing, determination of market prices, support in tax audits and notices of controlled transactions.