STS has announced the deadline to submit 2024 transfer pricing report and notification of participation in an international corporate group of companies.
Regfollower Desk
Ukraine’s State Tax Service (STS) announced on 11 September that the deadline for filing transfer pricing reports for the 2024 tax year on controlled transactions and notifications of participation in an international corporate group of companies has been set for 30 September 2025.
According to the Tax Code of Ukraine:
– Report on controlled transactions is submitted by payers who carried them out in 2024;
– Notification on participation in the international group of companies is submitted by payers who are members of the international groups of companies and carried out controlled transactions.
Reporting is submitted in the electronic form in compliance with requirements of the Laws of Ukraine “On electronic documents and electronic document management” and “On electronic identification and electronic trust services”.
Preparing documents, it is necessary to be guided by:
– Procedure for compiling Report on controlled transactions, approved by Order of the Ministry of Finance of Ukraine № 8 as of 18.01.2016 (with changes);
– Procedure for compiling Notification on participation in the international group of companies, approved by Order of the Ministry of Finance of Ukraine № 764 as of 14.12.2020 (with changes).
Particular attention should be paid to transactions with the non-residents’ permanent establishments. Such transactions are equated to transactions with non-residents for the transfer pricing purposes and recognised as controlled if criteria specified in the Tax Code of Ukraine are met.
At the same time, legislation provides for liability for failure to submit or untimely submission of reporting:
– for failure to submit Report on controlled transactions – UAH 908 400;
– for failure to submit Notification on participation in the international group of companies – UAH 302 800.
