On 18 September 2019, the State Tax Service (STS) of Ukraine explained about the procedure to file report on controlled transactions for transfer pricing purposes. According to the procedure, representative office that does not meet the conditions for qualifying as a permanent establishment (PE) will not considered as a corporate taxpayer. It is not necessary to submit a report on controlled transactions for such representative office. However, corporate taxpayers must submit a controlled transactions report to the tax authorities by 1 October of the year following the reporting year that have conducted controlled transactions.
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