Recently, the Ukraine State Fiscal Service (SFS) has explained about treatment of foreign exchange differences if controlled transactions meet the transfer pricing thresholds. Transactions are classified as controlled transactions if the annual income of the taxpayer exceeds UAH 150 million (approximately USD 5.2 million) within the reporting period, and the sum of the transactions with each counter party exceeds UAH 10 million (approximately USD 357,000).
SFS also explained that the income from operational foreign exchange differences is to be considered for the purpose of calculating the taxpayer’s annual income from any activity. On the other hand, income and expenses from operational foreign exchange differences are not to be considered for the purpose of calculating the sum of transactions of the taxpayer with each counter party.
