On 16 May 2017, the State Fiscal Service of Ukraine published a letter No. 9012/6/99-99-15-02-02-15 concerning the definition of related parties for the recognition of transactions controlled and guided by article 52 of the Tax Code of Ukraine.
The letter clarifies that for the purpose of the transfer pricing rules, a resident entity and non-resident entity will be deemed related if the entity directly and / or indirectly owns corporate rights in each such legal entity in the amount of 20 percent or more.