Transfer Pricing 2019 – Refining Rules under BEPS Terms

Currently, many countries have certain issues related to the payment of taxes, as existing rules enable businesses to use abusive practices with regard to tax rates, regulations, and benefits in different countries. To prevent this, the Organization for Economic Cooperation and Development (OECD) has developed recommendations with respect to combating tax evasion – BEPS Plan […]


Income Taxation Models for Permanent Representative Offices of Non-Residents (Ukrainian Law Firms 2018. A Handbook for Foreign Clients)

Income Taxation Models for Permanent Representative Offices of Non-Residents In general, for a non-resident operat­ing in Ukraine through a permanent representative office, the Tax Code of Ukraine provides for 3 (three) meth­ods of determining taxable income subject to taxation in Ukraine. However, since current tax legislation neither prioritizes application nor clearly regulates the criteria for […]

Transfer Pricing in 2017 — Improvement Under the Slogan of Liberalization

From 1 January 2017 Ukrain­ian tax legislation regulating transfer pricing has undergone changes, which generally can be evaluated as liberal and which were introduced in the interests of taxpayers. Here is the short list of changes. Increase of Cost Criterion to Recognize Transactions as Controlled This is definitely the most expected busi­ness standard. Preparation of […]

Inspections of controlled transactions pick up speed

According to the rules of the Tax Code of Ukraine,tax control in the sphere of transfer pricing is undertaken by monitoring and inspecting the calculation of completeness and of payment of income tax in controlled transactions. Such information, obtained during monitoring of economic activities, is the basis for decision adoption as of inspections conduct. According […]