The State Tax Service of Ukraine issued a notice on fines for specific transfer pricing reporting violations on 5 February 2025.
The penalty for failing to submit a notification of participation in a multinational group of companies has been increased from 50 to 100 subsistence minimums for an able-bodied person as of 1 January of the reporting year. However, the penalty for late submission of this notification has been reduced from 100 to 50 subsistence minimums (eighth paragraph of clause 120.6 of Article 120 of the Tax Code of Ukraine).
The penalty for late declaration of controlled transactions in a submitted report (if a revised report is filed) is set at 1 subsistence minimum per day of delay. However, the total penalty cannot exceed 300 subsistence minimums or 0.5% of the undeclared controlled transactions, whichever is lower (fourth paragraph of clause 120.6 of Article 120 of the Tax Code of Ukraine).
The new fines will take effect on 25 March 2025.
Earlier, the State Tax Service of Ukraine announced changes to the transfer pricing rules concerning the identification of related parties and controlled transactions on 31 December 2024.
