On September 7, 2017, the seminar entitled “Transfer Pricing: preparation of reports on controlled operations” organized by the Kherson Chamber of Commerce and Industry and the General Directorate of the State Fiscal Service in the Kherson region was held in Kherson.
The EUCON International Legal Center representatives Larysa Vrublevska, partner, head of transfer pricing, and Volodymyr Bevza, attorney, senior associate, deputy head of practice, were invited as speakers.
The head of the General Directorate of the State Fiscal Service in the Kherson region Ihor Klym opened the workshop, drew attention to the importance of getting acquainted with the latest innovations in the field of transfer pricing and wished everyone fruitful work.
Larysa Vrublevska described the justification of the price level in operations on purchase of goods from a non-resident on the example of the intermediary, indicating which criteria should be taken into account when choosing an appropriate transfer pricing method and which method should be given priority if it is possible to apply several methods at once. The participants were able to learn more about the algorithm for calculating the market margin of profitability in controlled transactions and with the peculiarities of making adjustments to the object of taxation.
Summarizing her presentation, Larysa advised the participants to prepare transfer pricing documentation in a timely manner, as this would allow to get ready for possible control measures.
Volodymyr Bevza spoke about the peculiarities of compliance inspections of controlled operations with the arm’s length principle and observance of transfer pricing rules, as well as the grounds for conducting them.
Volodymyr informed the participants about the future control trends in the field of transfer pricing, including the introduction of control over transactions with non-resident entities of certain organizational and legal forms (the list is provided in the Resolution of the Cabinet of Ministers of Ukraine №480), implementation of Action 13 of the BEPS plan, extension of the list of low tax jurisdictions, etc. Information on what the State Fiscal Service of Ukraine will pay attention to when monitoring transfer pricing was also important. The objects of such attention will be: operations with stock exchanges and financial transactions, increasing the level of inspections of large taxpayers, exchanging tax information with foreign tax administrations etc.
In conclusion, the speaker summed up the first results of judicial appeals against the decisions of the State Fiscal Service bodies, taken upon the results of transfer pricing audits
The event was attended by nearly 50 participants, including chief accountants, financial directors and lawyers of leading enterprises of the region.