New fines for the transfer pricing reporting violations

Press service of the State Tax Service of Ukraine, published 05 February 2025 at 12:44 Chapter: News

Changes to the Tax Code of Ukraine regarding new amounts of certain fines for violation of the transfer pricing reporting deadlines will come into force from March 25, 2025.

What should be taken into account?

- Fine for failure to submit notification on participation in the international group of companies has been increased from 50 to 100 subsistence minimums for an able-bodied person as of January 1 of the reporting year. For untimely submission of relevant notification, fine has been reduced from 100 to 50 subsistence minimums (Clause 8 Paragraph 120.6 Article 120 of the Tax Code of Ukraine).

-Fine for untimely declaration of controlled transactions in the submitted report on controlled transactions (if a clarifying report is submitted) is 1 subsistence minimum for each day of delay. However, total amount of fine cannot exceed 300 subsistence minimums or 0.5% of the amount of undeclared controlled transactions, and the lesser value shall be applied (Clause 4 Paragraph 120.6 Article 120 of the Tax Code of Ukraine).

Important: fines based on the audit results conducted by the controlling authorities are applied in amounts that are in effect at the time of decision to apply them.

Be careful and submit reports on time!