Representatives of the State Tax Service improve the transfer pricing control skills

Press service of the State Tax Service of Ukraine, published 18 April 2025 at 14:30 Chapter: News

Representatives of the State Tax Service of Ukraine and its territorial bodies participated in a training event on tax control over the transfer pricing.

Event took place in London as a part of the Tax Inspectors Without Borders (TIWB) program, initiated by Revenue Agency of the United Kingdom of the Great Britain and Northern Ireland.

Representatives of the Ministry of Finance of Ukraine and experts from the United Kingdom, France and Sweden discussed approaches to verifying controlled transactions with intangible assets and intra-group services, in particular, using financial capacity test, analysis of companies’ functional profiles, assessment of reasonableness of costs and reality of provided services.

Ukrainian party presented practical cases, specifically regarding royalty and intra-group services transactions. Together with the international experts, typical schemes used in controlled transactions were developed.

The following were also discussed:

approaches to determining marketability of interest rates under the loan agreements concluded between related parties,

calculating methodology of the borrower's credit rating within the group, taking into account its role as a budget-forming enterprise that accumulates major assets, resources and controls major functional risks.

In turn, representatives of the Tax Service of the United Kingdom presented approaches to organizing effective control over the transfer pricing, aimed at preventing tax base erosion and tax evasion.

Participants also learned about the Sweden’s experience in controlling non-performing loans (NPL) transactions within framework of the international group transactions. Experts shared approaches to assessing financial capacity and risk control ability of the non-resident counterparties, which allowed for a reasonable redistribution of profits in favor of the Swedish company.

Parties, following the event, agreed to continue cooperation and exchange of experience to form sustainable positive practices in the transfer pricing.

The TIWB program is effective platform for exchanging experience, implementing the best international approaches, and integrating Ukraine into the global system of tax standards. State Tax Service will continue to actively participate in the international dialogue to enhance effectiveness of control and strengthen tax culture.