Actual transfer pricing aspects were discussed during a joint webinar "Tax tango: Transfer pricing and controlled foreign companies" with participation of representatives of the State Tax Service, Deloitte experts and business.
Key legislative changes that came into effect on January 1, 2025 were discussed during event, including:
introduction of the economic nexus criterion;
updating lists of jurisdictions and organizational and legal forms;
reporting by the international groups of companies;
current case law.
"State Tax Service understands that business in Ukraine seeks predictability, clear rules and equal conditions for all. That is why the State Tax Service is actively developing modern analytical approaches, implementing digital solutions to improve quality of analysis, identify risks and at the same time minimize interference where business operates in a good faith" – stated First Deputy Head of the State Tax Service Lesia Karnaukh.
According to her, among the analytical tools currently used by the State Tax Service are:
Big Data TP to identify the transfer pricing risks;
analysis of financial and behavioral indicators;
comparison of functions, assets and profitability of taxpayers;
international information exchange to verify economic capacity of the non-resident counterparties.
"Our focus is shifting from simply checking numbers to a deep essence understanding of operations, business models and economic value that companies create. We understand that only cooperation, frank discussion and mutual respect will help us achieve synergy within the framework of public-private partnerships" – said Lesia Karnaukh.
Event participants got acquainted with mechanisms by which the State Tax Service analyzes controlled transactions, identifies risks and uses requests to international partners.
Lesia Karnaukh emphasized that the State Tax Service is open to constructive dialogue and cooperation to bring the transfer pricing system in line with the best global standards.