Representatives of the State Tax Service took part in international educational and practical seminar on the transfer pricing

Representatives of the State Tax Service of Ukraine at invitation of the Organization for Economic Cooperation and Development (hereinafter – OECD) took part in a workshop (educational and practical seminar) on the topic: "Transfer Pricing Train-the-Trainer Workshop Selected Topics".

The specified workshop is a part of course of training program on the basics of transfer pricing and is aimed at improving professional competencies of its participants, expanding knowledge in control over foreign economic activity, establishing international relations for further exchange of experience.

Representatives of tax authorities from 11 countries of the world received qualified expert assistance on the application of tax control over the transfer pricing, namely in relation to:

conducting functional analysis (FAR) as a basis for determining functional profile and business model of parties to the controlled operations;

establishing synergy effect assessing the transfer pricing risks;

analysis of operations with intangible assets, including by applying assessment methods and profit distribution;

methodology for determining risks of non-compliance with the "arm's length" principle in operations related to business restructuring.

In addition, practical cases regarding operations with intangible assets, intra-group services and business operations, as a result of which there was a transfer of potential profit and/or a change in place of effective management, were considered, within the framework of applying approaches of the OECD Guidelines in edition 2022 and taking into account specifics of the national legislation of countries – workshop participants.

During exchange of experience with countries participating in the seminar, representatives of the State Tax Service were informed about activities aimed at improving the transfer pricing rules, taking into account the latest global practices, and about development of information and communication system designed to process large amounts of data and identify the transfer pricing risks.

Meeting, in general, was productive for all its participants and experience gained will contribute to improvement of the transfer pricing control in the future and will be taken into account in the process of considering relevant legislative initiatives.

Representatives of the State Tax Service of Ukraine at invitation of the Organization for Economic Cooperation and Development (hereinafter – OECD) took part in a workshop (educational and practical seminar) on the topic: "Transfer Pricing Train-the-Trainer Workshop Selected Topics".

The specified workshop is a part of course of training program on the basics of transfer pricing and is aimed at improving professional competencies of its participants, expanding knowledge in control over foreign economic activity, establishing international relations for further exchange of experience.

Representatives of tax authorities from 11 countries of the world received qualified expert assistance on the application of tax control over the transfer pricing, namely in relation to:

conducting functional analysis (FAR) as a basis for determining functional profile and business model of parties to the controlled operations;

establishing synergy effect assessing the transfer pricing risks;

analysis of operations with intangible assets, including by applying assessment methods and profit distribution;

methodology for determining risks of non-compliance with the "arm's length" principle in operations related to business restructuring.

In addition, practical cases regarding operations with intangible assets, intra-group services and business operations, as a result of which there was a transfer of potential profit and/or a change in place of effective management, were considered, within the framework of applying approaches of the OECD Guidelines in edition 2022 and taking into account specifics of the national legislation of countries – workshop participants.

During exchange of experience with countries participating in the seminar, representatives of the State Tax Service were informed about activities aimed at improving the transfer pricing rules, taking into account the latest global practices, and about development of information and communication system designed to process large amounts of data and identify the transfer pricing risks.

Meeting, in general, was productive for all its participants and experience gained will contribute to improvement of the transfer pricing control in the future and will be taken into account in the process of considering relevant legislative initiatives.