In Re (#09 September 2015)

Comparable Uncontrolled Price Method

Ivan V. Shynkarenko, Kateryna V. Utiralova

From 1 January 2015, new version of Article 39 sets out the revised transfer pricing control system. On 7 July 2015, the Verkhovna Rada of Ukraine adopted other amendments of this Article and they have already been signed by President Petro Poroshenko.

Article 39 contains probably the most heavily amended rules of the Tax Code. At the same time, one rule that remains unchanged is the priority of the comparable uncontrolled price (CUP) method over other methods of transfer pricing...

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