Large taxpayers can agree on pricing in controlled transactions in advance
Press service of the State Tax Service of Ukraine , published 09 January 2026 at 14:41 Chapter: News
Procedure for advance agreement (АРА, Advance Pricing Agreement) on pricing in controlled transactions provides large taxpayers with opportunity to conclude agreement with the controlling authority on terms of determining prices in controlled transactions before they begin.
This is one of modern tools for resolving disputes within the framework of bilateral agreements on the avoidance of double taxation.
APA procedure has been implemented into Ukrainian tax legislation according to the international standards and best global practices to counter aggressive international tax planning schemes and create fair and competitive tax environment.
The main advantages of the APA procedure
Predictability of the tax base. APA allows large taxpayers to obtain agreed rules for determining terms of controlled transactions before they begin, which reduces tax risks in the future.
Tax certainty and stability. Terms of the APA agreement are protected from changes in tax legislation regarding the transfer pricing: even if the norms change, these terms remain valid for duration of the agreement.
Avoiding disputes. APA allows the payer to avoid disputes with the State Tax Service regarding methods, information sources and criteria for determining the “arm’s length” principle in the future, provided that controlled transactions remain unchanged.
Compliance with international standards. APA complies with the OECD Transfer Pricing Guidelines, which contributes to the Ukraine’s integration into the international tax community.
Documents governing the APA
Tax Code of Ukraine (Paragraph 39.6 Article 39).
Resolution of the Cabinet of Ministers of Ukraine № 1114 as of 28.10.2021 “On approval of the Procedure for preliminary coordination of pricing in controlled transactions, results of which lead to the conclusion of contracts of the unilateral, bilateral and multilateral essence for the transfer pricing purposes”.
Detailed information regarding Procedure for conducting advance pricing agreement in controlled transactions can be found at the link: