Changes that systematize rules for the raw materials came into effect on October 1

Press service of the State Tax Service of Ukraine, published 01 October 2025 at 16:44 Chapter: News

Law of Ukraine № 4536-IX, which clarifies procedure for applying term “quoted prices” in the transfer pricing, entered into force on October 1, 2025.

Document specifies that this term is used to control operations with the raw materials for reporting periods starting from January 1, 2021. That is, not new rules have been introduced – it is only a matter of systematizing already existing approach introduced by the Law of Ukraine № 466-IX.

Law of Ukraine №4536-IX specifies that:

- special rules for applying quoted prices for operations with the raw materials are in effect from 2021;

- for periods until 2021 – general provisions of the Tax Code of Ukraine regarding the priority transfer pricing methods and permissible sources of information apply.

Such changes are aimed at unifying approaches and increasing predictability in the regulation of controlled transactions with the raw materials.

Reminder:

- obligatory application of the comparative uncontrolled price method for operations with the raw materials was established in 2020, and the list of relevant products was approved by Resolution of the Cabinet of Ministers of Ukraine № 1221 as of 09.12.2020;  

- quoted prices became obligatory reference point for analyzing such operations from January 1, 2021;

- general rules of Article 39 of the Tax Code were in force until 2021, which allowed use of open data sources, in particular, stock quotes, price indicators and information and analytical materials, etc. to confirm the marketability of controlled transactions.

For reference.

Law of Ukraine № 4536-IX as of 16.07.2025 “On amendments to the Tax Code of Ukraine and other legislative acts of Ukraine in connection with adoption of the Law of Ukraine “on integrated prevention and control of industrial pollution” and in order to improve certain provisions of tax legislation”.

Law of Ukraine № 466-IX as of 16.01.2020 “On amendments to the Tax Code of Ukraine to improve tax administration, eliminate technical and logical inconsistencies in tax legislation”.

Resolution of the Cabinet of Ministers of Ukraine № 1221 as of 09.12.2020 “On approval of the list of raw materials and recognition as invalid Resolution of the Cabinet of Ministers of Ukraine № 616 as of 08.09.2016”.