Transfer Pricing

With the adoption of the new regulation on transfer pricing in Ukraine (effective since 1 September 2013), our transfer pricing practice was established. The practice is headed by Larysa Vrublevska, partner, and includes attorneys, auditors and professional appraisers. The combination of their diverse expertise enables us to follow comprehensive approach and be responsive at all stages of clients’ requests.

International Legal Center EUCON is a member of TPA Global, the network of independent specialist providers of expert transfer pricing, tax valuation and customs services. Our membership reinforces our capacities on the local market with cross-border capabilities of the association.

EUCON was recognized as The Best Transfer Pricing Firm in 2016 at the Ukrainian Legal Awards.

EUCON won the Ukraine Transfer Pricing Firm of the Year award at the annual European Tax Awards 2015.

Our services include the following:

  1. Development of the report on controlled transactions:
    • audit (inventory) of business transactions in order to identify controlled transactions;
    • identification of the transactions with unrelated counterparties that can be used as comparables due to their terms and prices;
    • providing recommendations on optimization of the structure of intra-group transactions.
  2. Development of the transfer pricing documentation:
    • diagnosis of controlled transactions;
    • search for comparables;
    • determination of the price level in controlled transactions. Calculation of the price range / Analysis of the market profitability level;
    • preparation of a written report (a complete package of documents for submission to the regulatory authority).
  3. Comparative analysis of the controlled party’s activities with the activities of comparable companies (benchmarking), using Bureau van Dijk databases:
    • diagnosis of controlled transactions;
    • search for comparables;
    • determination of the price level in controlled transactions. Calculation of the price range / Analysis of the market profitability level.
  4. Support during the transfer pricing inspections:
    • all the necessary information is prepared in a timely manner;
    • representation of the company at the bodies of the State Fiscal Service of Ukraine.
  5. Providing transfer pricing consultations:
    • on application of tax legislation;
    • on preparation of the report and documentation;
    • on tax planning and organizational structuring.
  6. Development and adaptation of the companys internal rules (policies) to control compliance with the transfer pricing legislation:
    • analysis of specific features of the company’s activity;
    • development of the procedures to identify controlled transactions;
    • identification of factors influencing the formation of prices and the search criteria for comparable transactions;
    • choice and justification of the method to determine the compliance of the price to the arm’s length principle for each type of transactions, preparation of the algorithm for its application;
    • identification of the sources of information that can be used by the company in view of the company’s specific features;
    • development of the procedure for preparing the documentation in order to justify prices in controlled transactions;
    • distribution of roles and responsibilities between the company’s employees at each stage of control.
  7. Support of transfer pricing disputes during administrative or judicial appeals of decisions of the regulatory authorities:
    • mediation on the stage of administrative appeal;
    • comprehensive legal support during the consideration of transfer pricing cases in court.
  8. Legal support during procedures of preliminary coordination of pricing in controlled transactions with the State Fiscal Service of Ukraine:
    • analysis of specific features of the company’s activity;
    • preparation of the application to the State Fiscal Service of Ukraine and the complete package of documents for its consideration;
    • comprehensive support during procedures of contract conclusion with the State Fiscal Service of Ukraine.
  9. Training of specialists from enterprises:

Transfer Pricing WORKSHOPS

Partnership

Awards