Deadline for submitting the transfer pricing reports for 2024 is September 30, 2025

State Tax Service of Ukraine reminds of the need to submit the transfer pricing reports on time. The last day to submit these documents for the reporting year 2024 is September 30, 2025.

According to the Tax Code of Ukraine:  

- Report on controlled transactions is submitted by payers who carried them out in 2024;

- Notification on participation in the international group of companies is submitted by payers who are members of the international groups of companies and carried out controlled transactions.

Reporting is submitted in the electronic form in compliance with requirements of the Laws of Ukraine “On electronic documents and electronic document management” and “On electronic identification and electronic trust services”.

Preparing documents, it is necessary to be guided by:

- Procedure for compiling Report on controlled transactions, approved by Order of the Ministry of Finance of Ukraine № 8 as of 18.01.2016  (with changes);

- Procedure for compiling Notification on participation in the international group of companies, approved by Order of the Ministry of Finance of Ukraine № 764 as of 14.12.2020 (with changes).

Particular attention should be paid to transactions with the non-residents’ permanent establishments. Such transactions are equated to transactions with non-residents for the transfer pricing purposes and recognized as controlled if criteria specified in the Tax Code of Ukraine are met.

At the same time, legislation provides for liability for failure to submit or untimely submission of reporting:

- for failure to submit Report on controlled transactions – 908 400 UAH;

- for failure to submit Notification on participation in the international group of companies – 302 800 UAH.

For convenience, please familiarize yourself in advance with reporting filling algorithms posted on the State Tax Service’s web portal at the links below:

- materials regarding Report on controlled transactions,

- materials regarding the Notification on participation in the international group of companies.

Taxpayers are urged to submit the transfer pricing reports in a timely manner and comply with the established requirements.

For reference:

According to Sub-paragraph "a" of Sub-paragraph 14.1.122 Paragraph 14.1 Article 14 of the Code, non-residents are foreign companies, organizations, partnerships and other associations of persons established according to legislation of other states, their branches, representative offices and other separate divisions located in the territory of Ukraine registered (accredited or legalized) according to legislation of Ukraine, as well as legal entities without the legal entity’s status established according to legislation of foreign states or territories that are not residents of Ukraine, according to provisions of the Code.

Designation of a permanent establishment as the taxpayer does not change its status as the non-resident, therefore, transactions of resident with a permanent establishment of the non-resident in Ukraine are equated to transactions with the non-resident for the transfer pricing purposes.

Therefore, if business transactions carried out by the taxpayer with a permanent establishment of the non-resident meet criteria established in Sub-paragraphs 39.2.1.1, 39.2.1.4, 39.2.1.7 of Sub-paragraph 39.2.1 Paragraph 39.2 Article 39 of the Code, such transactions will be recognized as controlled.

At the same time, criteria provided for in Sub-paragraphs "c" and "d" of Sub-paragraph 39.2.1.1 Sub-paragraph 39.2.1 Paragraph 39.2 Article 39 of the Code apply specifically to the non-resident who carries out economic activities in the territory of Ukraine through a permanent establishment.

In this regard, Information on the person carrying out controlled transactions, in the Report on controlled transactions, includes data on the non-resident’s counterparty in its country of registration.