Lesya Karnaukh: volume of controlled transactions for 2024 increased by a third – 3.3 trillion UAH was declared

As of early October, the taxpayers sent 2 797 reports on controlled transactions for 2024 to the State Tax Service. This is 11% more than for the same period last year. 

Declared amount is 3.3 trillion UAH. It is 32% higher than the previous reporting year. This was informed by acting Head of the State Tax Service Lesya Karnaukh on the Facebook page. 

The biggest number of controlled transactions was carried out with non-residents registered in:

- Austria – 18%;

- Switzerland – 17%;

- France – 11%;

- Netherlands – 10%;

- USA – 6%;

- Germany and Cyprus – 5% each.

By transactions type, the following prevail:

- with products – 49% (including with raw materials – 19%);

- banking services – 28%;

- financial services – 11%;

- services – 7%;

- transactions with securities – 4%;

- others – 1 %.

“To check compliance with the “arm’s length” principle, business entities the most often apply comparative uncontrolled price method, namely 62%, as well as the net profit method – 35% and resale price/costs plus/profit split method – 3%” – she added. 

In addition, 1 754 taxpayers reported about participation in the international groups of companies.

The biggest number of parent companies is registered in Cyprus (20%), United States (12%), Germany (10%), France (5%) and Switzerland (4%).

Taxpayers also exercised their right to independently adjust prices of controlled transactions and amounts of tax liabilities. They submitted the transfer pricing annexes to their corporate income tax declarations for 2024 for 2.7 billion UAH. This is 60% of all adjustments made in 2025.

“We continue our systematic work on increasing transparency, un-shadowing and ensuring equal competitive conditions for business” – Lesya Karnaukh emphasized. 

For reference:

Criteria for recognizing persons as related due to the so-called economic connection have been expanded From January 1, 2025 according to the Law of Ukraine № 3813-IX as of 18.06.2024 “On amendments to the Tax Code of Ukraine regarding the tax administration peculiarities during the martial law for taxpayers with a high level of voluntary compliance with tax legislation”. 

New approaches to formation of the lists have been introduced according to Resolutions of the Cabinet of Ministers of Ukraine № 1307 as of 15.11.2024 “On amendments to Resolution of the Cabinet of Ministers of Ukraine № 480 as of 04.07.2017” and № 1505 as of 27.12.2024 “On amendments to Resolution of the Cabinet of Ministers of Ukraine № 1045 as of 27.12.2017”. On the application of updated lists for transfer pricing purposes from January 1, 2025, on the official website of the Ministry of Finance of Ukraine - at the link: https://mof.gov.ua/uk/news/minfin_vazhlivi
_aspekti_zastosuvannia_onovlenogo_pereliku_derzhav_dlia_tsilei_transfertnogo_tsinoutvorennia-5006.

From October 1, 2025, the Law of Ukraine № 4536-IX as of 16.07.2025 “On amendments to the Tax Code of Ukraine and other legislative acts of Ukraine in connection with adoption of the Law of Ukraine “On the integrated prevention and control of industrial pollution” and in order to improve certain provisions of tax legislation” came into force, which clarified procedure for applying term “quoted prices” in the transfer pricing. Document specifies that this term is used to control transactions with raw materials for reporting periods starting from January 1, 2021. That is, no new rules have been introduced - it is only about systematizing already existing approach introduced by the Law of Ukraine № 466-IX “On amendments to the Tax Code of Ukraine to improve tax administration, eliminate technical and logistic inconsistencies in tax legislation”.