The State Fiscal Service (SFS) recently published Guidance Letter No. 517/Г/99-99-12-03-07-14 of 16 January 2017, the State Fiscal Service (SFS) clarified which sources of information should be used for transfer pricing purposes according to the Tax Code.

SFS clarified that as long as there is no officially approved list of sources of information, taxpayers and tax authorities may use any information available from public sources. However, the SFS emphasized that tax authorities are not authorized to determine any special sources of information which should be used by taxpayers for transfer pricing purposes in particular upon a taxpayer’s request.