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.

Our services include the following:

  1. Audit (inventory) of business transactions in order to identify controlled transactions.

This will result in:

  • Development of a register of controlled transactions over a specified period;
  • Recommendations to optimize the structure of intra-group transactions;
  • Determination of the transactions with unrelated counterparties that can be used as transactions with comparable terms because of their prices.
  1. Development and adaptation of the company’s internal rules (policies) to control compliance with the legislation on transfer pricing.

This will result in:

  • Development of the procedures to identify controlled transactions;
  • Determining criteria of transaction comparability in view of specific features of the company;
  • Selection and justification of the pricing method, development of an algorithm of the method’s 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 justifying prices in controlled transactions;
  • Distribution of roles and responsibilities between the company’s employees at each stage of control.
  1. Development of the documentation on controlled transactions upon request of tax authorities (the State Fiscal Service of Ukraine – SFSU).

This will result in:

  • Generation of information on comparable transactions with unrelated persons;
  • Determination of the market price range (profitability) according to the pricing method of the company;
  • Justification of the contractual price;
  • Calculation of tax liability if the company adjusts the price independently;
  • Development of a complete set of documents for filing with regulatory authorities.
  1. Support during inspections in the field of transfer pricing.

We will ensure that:

  • The necessary information relevant to the inspections is prepared in a timely manner;
  • Representation of the company at the bodies of the State Fiscal Service of Ukraine.

Our recent experience includes comprehensive advising on transfer pricing of the following companies:

  • Public JSC Ukrrichflot, the major Ukrainian shipping corporation;
  • Zepter Ukraine, a subsidiary of Zepter International;
  • Selena LLC;
  • Louis Dreyfus Commodities Ukraine;
  • Plastics-Ukraine LLC and others.

In response to clients’ request the International Legal Center EUCON launched the Transfer Pricing School for financial managers and chief accountants. Our experts give lectures on the legislation on transfer pricing, its practical application, rendering case studies and major legal uncertainties. At present, the classes were attended by the employees from more than 150 Ukrainian and international companies. More about Transfer Pricing School.

Transfer Pricing WORKSHOPS