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Transfer Pricing

The regulation on transfer pricing in Ukraine is effective since 1 September 2013, and is rather complicated in its application. The last changes effective from 1 January 2015 were aimed, among others, at reduction of value criterion in recognition of controlled transactions, and broadened the range of taxpayers pertaining to this regulation.

The professionals of the International Audit Union have a substantial number of projects in the field of transfer pricing that enable our clients to develop transfer pricing control systems, justify prices in controlled transactions, and develop documents upon requests of the regulatory authorities.

We are ready to help and share our experience in the following cases:

  1. Development of the report on controlled transactions:
    • audit (inventory) of business transactions in order to identify controlled transactions;
    • identification of the transactions with unrelated counterparties that can be used as comparables due to their terms and prices;
    • providing recommendations on optimization of the structure of intra-group transactions.
  2. Development of the transfer pricing documentation:
    • diagnosis of controlled transactions;
    • search for comparables;
    • determination of the price level in controlled transactions. Calculation of the price range / Analysis of the market profitability level;
    • preparation of a written report (a complete package of documents for submission to the regulatory authority).
  3. Comparative analysis of the controlled party’s activities with the activities of comparable companies (benchmarking), using Bureau van Dijk databases:
    • diagnosis of controlled transactions;
    • search for comparables;
    • determination of the price level in controlled transactions. Calculation of the price range / Analysis of the market profitability level.
  4. Support during the transfer pricing inspections:
    • all the necessary information is prepared in a timely manner;
    • representation of the company at the bodies of the State Fiscal Service of Ukraine.
  5. Providing transfer pricing consultations:
    • on application of tax legislation;
    • on preparation of the report and documentation;
    • on tax planning and organizational structuring.
  6. Development and adaptation of the companys internal rules (policiesto control compliance with the transfer pricing legislation:
    • analysis of specific features of the company’s activity;
    • development of the procedures to identify controlled transactions;
    • identification of factors influencing the formation of prices and the search criteria for comparable transactions;
    • choice and justification of the method to determine the compliance of the price to the arm’s length principle for each type of transactions, preparation of the algorithm for its application;
    • identification of the sources of information that can be used by the company in view of the company’s specific features;
    • development of the procedure for preparing the documentation in order to justify prices in controlled transactions;
    • distribution of roles and responsibilities between the company’s employees at each stage of control.
  7. Support of transfer pricing disputes during administrative or judicial appeals of decisions of the regulatory authorities:
    • mediation on the stage of administrative appeal;
    • comprehensive legal support during the consideration of transfer pricing cases in court.
  8. Legal support during procedures of preliminary coordination of pricing in controlled transactions with the State Fiscal Service of Ukraine:
    • analysis of specific features of the company’s activity;
    • preparation of the application to the State Fiscal Service of Ukraine and the complete package of documents for its consideration;
    • comprehensive support during procedures of contract conclusion with the State Fiscal Service of Ukraine.
  9. Training of specialists from enterprises: