On 29 March 2019, the State Fiscal Service (SFS) of Ukraine issued letter 1358/6/99-99-15-02-15/ІPK on the treatment of salary payments to non-resident persons as controlled for transfer price purposes.
The letter states that such payments are considered controlled when the standard thresholds for the year are met. This implies that the annual income of the Ukrainian taxpayer exceeds 150 million UAH, and the annual transactions (salary payments) with the non-resident exceed 10 million UAH (~ 376,000 USD). Thus, when the thresholds are reached, salary payments must be included in the annual report on the transactions under review and determined using the arm’s length principle.
