Specialists of the State Tax Service shared their experience in the transfer pricing at the international OECD training

Ukraine continues actively integrate into the global space of the best tax practices, particularly in the ​​transfer pricing sphere.

Representatives of the State Tax Service of Ukraine and Ministry of Finance participated in the educational and practical seminar "Transfer Pricing Train-the-Trainer Workshop: Selected Topics", organized by the Organization for Economic Co-operation and Development (OECD). Event was held in the Ankara (Republic of Turkey) and brought together participants from 12 jurisdictions.

Ukrainian delegation presented practical case study in which analyzed how marketing expenses incurred by a foreign related company affect determination of profitability in controlled transactions. Application of the non-resident counterparty economic capacity test in combination with the in-depth functional analysis made it possible to carry out reasonable division of profit between the related parties.

This example aroused considerable interest among the participants and became subject of active discussion.

Also among the questions considered during the seminar:

application of the profit distribution method,

analysis specificities of the intragroup loans, transactions with intangible assets,

functional analysis with the distribution of functions, assets and risks between the parties of controlled transactions.  

Attention was paid to methods of collecting reliable information, particularly by interviewing participants of controlled transactions.

Participation in the seminar provided Ukrainian specialists not only with opportunity to present their analytical approaches, but also to obtain information about the new tools for improving quality of the transfer pricing control, preparing methodological recommendations, and improving legislative norms.