The State Fiscal Service (SFS) on 4 January 2017 issued Guidance Letter No. 29/6/99-99-15-02-02-15 clarifying the procedure for transfer pricing adjustments by corporate income taxpayers that are required to file quarterly returns.
According to tax code article of 39, corporate income taxpayers can determine only at the end of the fiscal year whether their transactions with related entities should be considered controlled.
Consequently, corporate income taxpayers that are required to file quarterly returns must report transfer pricing adjustments in the corporate income tax return submitted for the last reporting quarter of that fiscal year.
