The transfer pricing rules introduced by Ukraine from 1 January 2013 provide for the possibility of negotiating advance pricing agreements with the tax authorities. The Ukraine Ministry of Finance has approved an information form concerning related parties, to be filed by large taxpayers along with an advance pricing agreement (APA) application. The definition of a large taxpayer for the purpose of the rules on negotiating APAs is an entity with income above UAH 500 million in the four preceding quarters or which has paid total taxes exceeding UAH 12 million in the period.
The APA establishes the transfer pricing method to be used in relation to certain specified transactions and the sources of information that may be used by the taxpayer. Ministry of Finance Order No. 391 of 12 March 2013 authorizes the related-party information form, which is to be filed with the tax authorities (i.e., the Ministry of Revenues and Duties). Large taxpayers are directed to submit this information form to the tax authorities along with their applications for an APA.
