Specialists of the State Tax Service have improved approaches to controlling transfer pricing in financial transactions

Press service of the State Tax Service of Ukraine, published 20 October 2026 at 13:46 Chapter: News

Determining economic substance of the intra-group loans, distinguishing between debt financing and capital contributions, analyzing comparability of transactions and applying the transfer pricing methods were the main topics of training and practical seminar in Warsaw.

Event was organized by the Organization for Economic Co-operation and Development (OECD) in cooperation with the Ministry of Finance of Poland. It was the second in-person workshop within framework of the Ukraine capacity building program on the analysis of financial transactions in transfer pricing.

Seminar participants were representatives of the State Tax Service of Ukraine, Economic Security Bureau of Ukraine and international experts from the Organization for Economic Cooperation and Development (OECD), UK Revenue and Customs Service (HMRC), Australian Taxation Office, Tax Inspectors Without Borders (TIWB) program and the Ministry of Finance of Poland.

Participants, during the practical sessions, worked out approaches to determining economic content of intragroup loans, assessing their terms, conditions and establishing compliance with the arm’s length principle.

Particular attention was paid to the distinction between debt financing and capital contributions, comparability analysis, finding comparable transactions and applying transfer pricing methods.

Specifics of financial guarantees and centralized management of cash of the group of companies were also considered.

Methodological basis of discussions was the OECD Transfer Pricing Guidelines, in particular Section X, dedicated to financial transactions. During the practical work, international approaches were considered taking into account economic conditions of Ukraine.

Knowledge gained and exchange of experience with international experts will contribute to improving practical skills of the State Tax Service’s specialists and improving tax control quality over financial transactions.