The autumn season of legal events ended with a round table “Topical issues of transfer pricing. SFS and taxpayers: confrontation or cooperation on controversial issues”, which took place on November 30, 2018. The organizer of the Event is the APA Committee on Tax and Customs Law. Particularly, Larysa Vrublevska was the round-table participant, an auditor, the partner, the manager of the transfer pricing practice of the EUCON Legal Group.
Thus, participants of the Event discussed the following issues: the methodology of tax control of transfer pricing; results of audits of controlled transactions focusing on the analysis of controversial issues and court decisions; criteria for the recognition of a business transactions controlled in the meaning of Article 39 of Tax Code of Ukraine; features of recognition of controlled transactions with non-residents from “low tax” jurisdictions and with non-residents that fall under the List of organizational and legal forms; recognition of controlled transactions provided by resident intermediaries; which is understood as “substantiation” of the use by the taxpayer of the method of establishing the conformity of conditions of controlled transactions with the principle of “arm’s length”; application of penalties for failure to submit or late submission of a report on controlled transactions, particularly in 2017 and 2018; the implementation of the BEPS plan in Ukrainian laws and its significance for taxpayers.
Iryna Zheltobriuch, judge of the Cassation Administrative Court in the Supreme Court, Vyacheslav Kruhliak, Deputy Head of the Transfer Pricing Audit Department of the SFS Audit Department also took part in the round table.