Letter of the State Fiscal Service of Ukraine № 1517/6/99-99-15-02-02-15 dd 07.08.2015

If the comparison of prices or profitability in a controlled transaction is carried out with prices or profitability indicators of two or more comparable uncontrolled transactions or legal entities that do not deal with related parties, the price range (profitability) has to be used. If the number of comparable uncontrolled transactions or legal entities that [...]

Letter of the State Fiscal Service of Ukraine №7384/6/99-99-15-02-02-15 from 10.04.2017

In accordance with the rules that came into force on January 1, 2017, the taxpayer has the right to independently adjust the price of the controlled transaction to a minimum or maximum value of the market range, and not to the median of the market range. Since these changes came into force on January 1, [...]

Letter of the State Fiscal Service of Ukraine №3698/6/99-99-12-03-07-15 from 22.02.2017

About commodities that have stock quotes: the Code does not contain any details as to the number of commodity exchanges to be selected to determine whether the conditions for controlled transactions with such goods are in line with the "arm's length" principle and do not set the priority of their application. For the purposes of [...]

Letter of the State Fiscal Service of Ukraine №1201/Г/99-99-15-02-02-14 from 24.01.2017

Financial indicators that have a negative value can be used to calculate the rate of return range if the research of the compliance of the uncontrolled transaction with the comparability criterion is carried out. In this case, the decision on the use of negative financial indicators is taken individually in each case of functional and [...]

Letter of the State Fiscal Service of Ukraine №1021/6/99-99-15-02-02-15 from 19.01.2017

1) A special procedure for establishing compliance with the conditions of the "arm's length" principle is specified for controlled transactions with stock commodities. For the purpose of applying a special rule, Tax Code of Ukraine defines an exclusive list of financial and business conditions that should be taken into account in order to ensure comparability [...]

Letter of the State Fiscal Service of Ukraine from 04.01.2017 №27/6/99-99-15-02-02-15

Financial indicators that have a negative value can be used to calculate the rate of return range if the research of the compliance of the uncontrolled transaction with the comparability criterion is carried out. In this case, the decision on the use of negative financial indicators is taken individually in each case of functional and [...]

Letter of the State Fiscal Service of Ukraine from 09.12.2016 №26705/6/99-99-15-02-02-15

Standards of Tax Code of Ukraine do not contain any restrictions on the period of selection of comparable uncontrolled transactions (before or after the date of execution of the controlled transaction). At the same time, the decision to determine a certain period (dates) for the selection of comparable uncontrolled transactions should be taken individually for [...]