Results of the transfer pricing reporting campaign

STS received 2 325 Reports on controlled operations, in which taxpayers provided information on controlled operations in the amount of 2.5 trillion UAH for 2020. Most controlled operations were carried out with non-residents of Switzerland (20%), France (19%), Netherlands (9%), Austria (8%) and the United Kingdom (7%).

For the first time in 2021, the taxpayers who carried out controlled operations are required to submit a notification on participation in the international group of companies by October 1 of year following the reporting year (hereinafter – Notification).

62% of taxpayers reported on belonging to the international group of companies (hereinafter – IGC) of the total number of submitted notifications. Taxpayers indicated Cyprus (21%), Germany (9%), USA (8%), France (5%), Switzerland (5%), Ukraine (4%) and other countries in terms of information regarding countries (territories) of tax residence of parent company of the IGC.

In pursuance of requirements of Sub-paragraph 39.5.4 Paragraph 39.5 Article 39 of the Tax Code of Ukraine, the number of 201 taxpayers independently adjusted the cost of controlled operations in the total amount of 2.6 billion UAH and increased amount of the income tax liabilities totaling 192 million UAH.

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