Transfer pricing: more than 100 companies independently adjusted their tax figures

Press service of the State Tax Service of Ukraine, published 30 June 2026 at 16:18 Chapter: News

More than 100 companies have independently adjusted prices of controlled transactions and amount of tax liabilities by over 3 billion UAH in 5 months of this year. Last year, this amount reached 6.3 billion UAH. These figures speak to the main thing – control over transfer pricing in Ukraine is moving to a new level.  

This was stated by acting Head of the State Tax Service of Ukraine Lesya Karnaukh during online webinar organized by the Deloitte Ukraine. Event was moderated by Oleksandr Yampolskyi, Head of Transfer Pricing Practice at Deloitte Ukraine.

“Efficiency of the State Tax Service is not measured by the number of audits or fines. For us, the main indicator is voluntary compliance. Because business that works honestly and transparently, fulfills its tax obligations, is a partner for us. And if business independently brings its transactions to the “arm’s length” principle, then the system is working correctly. And transition to the risk-oriented approach, to constant communication with business, is effective. Business understands: our analytical tools see risks even before the tax auditor contacts you” – Lesya Karnaukh said.  

State Tax Service departs from formal paper analysis and evaluates large amounts of information using the Big Data TP information system. This system uses more than 100 risk analysis algorithms. It automatically evaluates indicators of liquidity, solvency, structure of foreign exchange, compares profitability of the parties to the transaction with average industry levels and instantly highlights anomalies in pricing. 

One of such illustrative cases. For example, a company that operated in Ukraine later moved production abroad. Products began to be produced using Ukrainian technologies without compensation for the use of intellectual property, and profits were transferred to the non-resident in a country with preferential taxation. And this is example of a clear scheme of artificial transfer of the profit center. 

“By the way, every year we receive about 2.5 thousand reports on average. In 2025, there were 2.9 thousand reports, in which total volume of controlled transactions reached 3.3 trillion UAH. This is a colossal array of data that is impossible and economically inexpedient to check “blindly” – she added. 

According to Lesya Karnaukh, the State Tax Service also clearly understands what concerns businesses today. And it does everything to ensure that working conditions are predictable.

During event, the draft law was discussed, which implements the OECD standards and the BEPS Action Plan, expands range of controlled transactions and tightens transfer pricing requirements. State Tax Service clearly understands that the range of controlled transactions will expand, new categories of transactions will come under control. But the change in the focus of control will be directed at the real risks of aggressive tax planning.

The full launch of the Country-by-Country Reporting (CbC) mechanism significantly changes the situation. It allows to go beyond local vision and see the global picture, where the company’s profit, real employees and assets are located. We actively integrate the latest tools such as electronic SAF-T audit and reports on controlled foreign companies.

“Our important task, despite all the challenges, is to build tax system that will be understandable for a conscientious investor and at the same time will not leave opportunities for artificially withdrawing profits from Ukraine” – added acting Head of the State Tax Service.

Watch the webinar recording at the link: https://deloi.tt/4oXhjC1