These amendments, which took effect on 25 March 2025, adjust the penalties applicable to late or missing submissions of TP-related reports and notifications.

The Ukrainian State Fiscal Service issued a clarification on upcoming changes to the Tax Code related to fines for transfer pricing (TP) reporting violations on 5 February 2025.

These amendments, which took effect on 25 March 2025, adjust the penalties applicable to late or missing submissions of TP-related reports and notifications.

Increased fine for non-submission of group participation notification

Companies that fail to submit the mandatory notification of participation in an international group of companies will now face a fine of 100 subsistence minimums for an able-bodied person, up from the previous 50. The applicable amount is determined based on the subsistence minimum as of 1 January of the reporting year.

Reduced fine for late submission of group participation notification

In contrast to the stricter penalty for non-submission, the fine for untimely submission of this notification has been reduced from 100 to 50 subsistence minimums. This change is set out in Clause 8, Paragraph 120.6, Article 120 of the Tax Code of Ukraine.

Penalties for late declaration of controlled transactions

If a company fails to timely declare controlled transactions in its transfer pricing report but later submits a clarifying report, a penalty of 1 subsistence minimum per day of delay will apply. However, the fine is capped at the lesser of:

  • 300 subsistence minimums, or
  • 0.5% of the amount of undeclared controlled transactions.

This provision is outlined in Clause 4, Paragraph 120.6, Article 120 of the Tax Code.

Audit-based fines

If penalties are assessed following a tax audit by the controlling authorities, the fine amounts in force at the time of the decision will apply. This means businesses should remain vigilant about any future changes to penalty rates.

Earlier, the State Tax Service issued a notice regarding fines for specific transfer pricing reporting violations on 5 February 2025.