Transfer Pricing

Transfer pricing is one of the most complex and important components of tax legislation and is one of the priority areas of tax audits in Ukraine. The significant size of potential tax penalties and the renewal of tax audits related to transfer pricing during the state of war confirm its growing importance.

In Ukraine, as in many other countries, transfer pricing rules are constantly changing, which can lead to tax risks for taxpayers. Experts of Mazars Ukraine have many years of experience in transfer pricing, constantly monitor changes in legislation, and are always ready to help you with all questions regarding this complex tax regime.

Mazars Ukraine offers a wide range of transfer pricing services, including:

  • Identification of controlled transactions
  • Consultation on the application of transfer pricing rules
  • Development of intra-group Transfer Pricing Policies
  • Audit of transfer pricing documentation (Local Files)
  • Transfer pricing compliance audit
  • Preparation of reports on controlled transactions
  • Preparation of notifications on participation in Multinational entities
  • Preparation of transfer pricing documentation
  • Preparation of Country-by-Country reports (CbC Reporting)
  • Preparation of Master Files
  • Analysis and justification of the business purpose of the controlled transactions
  • Support of tax disputes related to the application of transfer pricing rules
  • Preparation of documentation to justify prices or profitability to avoid tax adjustments under paragraphs 140.5 of Article 140 of the Tax Code of Ukraine
  • International business restructuring considering transfer pricing requirements.