Safe Harbors in Transfer Pricing Regulations

Olena V. Voznyuk

Anumber of countries have already adopted Transfer Pricing (TP) rules and are continually increasing their TP compliance requirements. Ukraine joined the list in 2013. Although TP rules in most countries are in line with the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (OECD TP Guidelines), many countries have unique TP rules and TP documentation requirements. In order to simplify compliance requirements and reduce the number of TP audits and disputes, the OECD has announced an initiative to simplify and harmonize the TP requirements, and the “safe harbor” regime was among such initiatives...