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Payer’s provision of transfer pricing documentation at the request of regulatory authorities during the quarantine period

, published 21 September 2021 at 11:20

Order of the Ministry of Finance of Ukraine as of 20.08.2021 № 478 to eliminate ambiguous interpretation of tax legislation approved the General Tax Consultation on the temporary suspension of taxpayers’ responses to requests from regulatory authorities to submit the transfer pricing documentation.

Specifically, the General Tax Consultation stipulates that suspension of responses to the STS’s requests for the quarantine period established to prevent spread of coronavirus disease in Ukraine (COVID-19) is not applicable to submission of the transfer pricing documentation.

That is, in the case of request for transfer pricing documentation during the quarantine period, the taxpayer must provide such documentation within the standard period stipulated by legislation (30 calendar days).

It should be noted that absence of financial sanctions for violation of deadlines for submission of the transfer pricing documentation for the quarantine period does not preclude conduction of audits according to Sub-paragraph 78.1.15 Paragraph 78.1 Article 78 of the Tax Code of Ukraine.

Full text of the General Tax Consultation can be found at:   or on the web portal of the State Tax Service of Ukraine in “Transfer pricing” section.


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