Report on controlled transactions: how to reflect person relation code

Press service of the State Tax Service of Ukraine, published 10 June 2026 at 13:21 Chapter: News

Prior to changes to the Compiling procedure of Report on controlled transactions, taxpayers should use relation code 517 “Recognized as related parties independently”.

This code must be indicated in the process of compiling annex “Information regarding person participating in controlled transactions” if relation is determined according to the new economic criteria established by the Tax Code of Ukraine.

These are the cases where a significant part of the company’s income or purchases falls on one non-resident. Persons can be recognized as related if resident’s income from the sale of products, works or services to one non-resident is at least 75% of all income from transactions with non-residents. In this case, such income must be at least 50% of the company’s total income from the sale of products, goods, works or services.

Similar approach applies to purchasing transactions. Relation may arise if cost of products, works or services purchased from one non-resident is at least 75% of all purchases from non-residents. At the same time, volume of such purchases must be at least 50% of the total cost of products, works or services purchased by the company. 

Currently, valid Compiling procedure of Report on controlled transactions does not contain separate codes for such criteria. That is why it is recommended to temporarily use code 517.

In such case, it is not necessary to submit annex “Information regarding relation of persons" to the Report on controlled transactions.

In addition, in addition to the Report, the payer may indicate which specific relation criterion is applied. It is also possible to provide detailed information regarding volume of transactions with non-resident and other information confirming existence of relevant criterion.

Such clarifications are related to the introduction of new criteria for relation of persons, which were introduced into the Tax Code of Ukraine by the Law of Ukraine № 3813-IX as of 18.04.2024. At the same time, Ministry of Finance has already prepared changes to the Compiling procedure of Report on controlled transactions, which provide for the appearance of separate codes for new signs of relation.

More is at the link: https://tax.gov.ua/diyalnist-/transfertne-tsinoutvorennya-ta-mijnarodne-opodatkuvannya/transfertne-tsinoutvorennya/listi-rozyasnennya/80163.html