Representatives of the State Tax Service took part in a conference on topic: "Transfer pricing and Controlled foreign companies: International transparency or the total tax control?"

Representatives of the State Tax Service of Ukraine at invitation of the Public Organization "All-Ukrainian Accounting Club" took part in a conference on topic: "Transfer pricing and Controlled foreign companies: International transparency or the total tax control?", during which topical matters regarding the transfer pricing and controlled foreign companies were discussed.

Representatives of the State Tax Service presented the latest changes to the Tax Code of Ukraine, which were introduced during 2024, and also highlighted matters related to reporting and results of the transfer pricing declaration campaign and Country-by-country report of the international group of companies.

It was also about starting the process of monitoring submission of the Country-by-country reports (CbC) by taxpayers who are residents of Ukraine (parent companies) within framework of the Multilateral Agreement of Competent Authorities on Automatic Exchange of Country-by-country reports (CbC) (entered into force on July 4, 2024).

Discussion regarding international taxation practices was particularly interesting. Since, control over the Transfer pricing, Controlled foreign companies, taxation of non-resident incomes, activities of non-residents (including permanent representative offices) and exchange with foreign competent authorities is important and effective tool for protecting economic interests of our state, as well as means of blocking double or discriminatory taxation.

Participants, during the conference, discussed results of the declaration campaign of controlled operations, analysis of submitted Notifications and Reports on controlled foreign companies, development of risks and application of fines.

It was also informed about introduction of modern, innovative technologies and effective solutions aimed at improving taxation system in Ukraine and implementing tax control. An automated system for working with large arrays of data was created for risk analysis in the transfer pricing (Big Data TP), which allows to automatically process millions of data lines, integrate information from various systems, identify risks and monitor their development, generate operational data and collect system analytics.

Emphasis is placed on the State Tax Service's application of an integrated approach researching international taxation risks and strengthening measures to work out the so-called "hidden connection", as well as identifying potential controllers of the controlled foreign companies.

In addition, a lively discussion took place in the "open microphone" mode for more than 4 hours, during which business representatives received answers to urgent questions.

Held meeting was useful for its participants and aimed at improving open and reasonable dialogue between the State Tax Service and business representatives, including regarding independent adjustment and changes in approaches to the formation of taxation object through the compliance.