New tendency in transfer pricing: business voluntarily increased tax base by 3 billion UAH

Press service of the State Tax Service of Ukraine, published 26 June 2026 at 14:00 Chapter: News

More than 100 companies independently adjusted prices of controlled transactions and amounts of tax liabilities according to requirements of transfer pricing legislation during January – May 2026.

As a result of such voluntary adjustments, financial result before taxation was increased by more than 3 billion UAH. And this is not the result of audits or application of fines. Companies themselves corrected tax risks after analyzing their transactions.

Due to such adjustments, income tax accruals increased by more than 200 million UAH and negative value of taxable object decreased by more than 1.9 billion UAH.

Such indicators indicate effectiveness of the risk-based approach applied by the State Tax Service in the transfer pricing control.

The main goal of tax control over transfer pricing is to encourage business to independently adjust indicators in case of deviation from the “arm’s length” principle.

Systematic increase in the amount of voluntary adjustments demonstrates gradual change in the model of interaction between tax authorities and taxpayers. Business is increasingly choosing to fulfill their tax obligations independently, which is one of the key indicators of tax compliance development.