Expert Opinion (#09 September 2015)

Transfer Pricing 2015: Adaptation to Changes

Larysa V. Vrublevska

The current system of transfer pricing regulation in Ukraine is still being improved. The latest amendments to tax legislation introduced by the Act of 15 July 2015, No. 609-VIII that came into effect on 13 August 2015. Generally, with the help of the abovementioned Act several tasks have been completed. Namely, the drawbacks of the previous wording of Article 39 of the Tax Code of Ukraine are eliminated (for example, financial ratios list needed for the profitability calculation is brought back), and the new wording of some basic norms, including those regulating the definition of the controlled transactions, is presented. All amendments can be defined as quite liberal toward taxpayers. Although some fiscal details such as tripling of the penalty for the failure to submit reports are not avoided...

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