On 17 August 2022, the Ukrainian State Tax Service (STS) announced that the deadline for submitting transfer pricing (TP) reports on controlled operations and notifications on participation in the international group of companies for the reporting year 2021 is 30 September 2022.
The form and procedure for drafting are approved:
- Report on controlled transactions- by order of the Ministry of Finance of Ukraine № 8 as of 18 January 2016 (as amended);
- Notification of participation in an international group of companies- by order of the Ministry of Finance of Ukraine № 839 as of 31 December 2020 (as amended).
The obligation to report on controlled transactions remains, despite the fact that taxpayers who can confirm the lack of opportunity to submit reports in a timely manner are exempted from responsibility during martial law. The results of the analysis of the reports on the controlled transactions are used to make a decision to conduct an audit on the transfer pricing issues.
The STS recommends that in order not to receive a fine:
- to review the operations carried out for compliance with the “arm’s length” principle;
- submit a detailed calculation by 1 October 2022.
