Letter of the State Fiscal Service of Ukraine № 768/6/99-99-15-02-02-15 from 22.06.2017

The amount of non-repayable financial assistance granted (received) is taken into account when determining the value criterion of controlled transactions for transfer pricing purposes and is reflected in the Report on Controlled transactions with the transaction Name Code 034 of Appendix 3 to the Procedure for drawing up the Control Transactions report. More...

2017-07-11T12:10:03+00:00 11.07.17|Cost criterion|

Letter of the State Fiscal Service of Ukraine № 516/6/99-99-45-02-02-15 from 07.06.2017

The amount of loans granted (received) is not taken into account when determining the value criterion of controlled transactions for the purposes of transfer pricing. At the same time, the amount of accrued interest for such transactions is taken into account when determining the value criterion of controlled transactions. More...

2017-07-11T08:46:10+00:00 11.07.17|Cost criterion|

Letter of the State Fiscal Service of Ukraine № 21688/6/99-99-15-02-02-15 from 06.10.2016

Income from transactional and non-transactional exchange differences is taken into account for the calculation of annual income (50 mln. UAH.) of taxpayer from any activity for the purpose of value criterion and is not taken into account for calculating the volume of business transactions (5 mln. UAH.) of taxpayer with each counterparty for the purposes [...]

2017-07-11T08:44:44+00:00 11.07.17|Cost criterion|

Individual consultation of the Main Department of the State Fiscal Service of Ukraine in Mykolaivska region №2474/10/14-29-12-02-20 from 18.08.2016

For the determination of the criterion concerning the volume of the taxpayer's business transactions for the purposes of transfer pricing (over 5 million UAH with each counterparty), transactions in foreign currency  are accounted at the date of processing in the hryvnia equivalent. At the same time, exchange rate differences from the conversion of transactions denominated [...]

2017-09-25T14:44:21+00:00 11.07.17|Cost criterion|

Individual consultation of the Main Department of the State Fiscal Service of Ukraine in Mykolaivska region №2399/10/14-29-12-02-20 from 12.08.2016

For the determination of the criterion concerning the volume of the taxpayer's business transactions for the purposes of transfer pricing (over 5 million UAH with each counterparty), transactions in foreign currency  are accounted at the date of processing in the hryvnia equivalent. At the same time, exchange rate differences from the conversion of transactions denominated [...]

2017-07-11T08:39:56+00:00 11.07.17|Cost criterion|

Letter from the State Fiscal Service of Ukraine № 12970/6/99-99-15-02-02-15 from 10.06.2016

1) Since the value criterion of business transactions with each counterparty has been changed (set at UAH 5 million), then it is impossible to use the answer to Question 25 of the Summarizing Tax Advice on specific issues of applying the tax legislation on transfer pricing, approved by the Order of the Ministry of Income [...]

2017-09-25T14:43:00+00:00 11.07.17|Cost criterion|

Letter from the State Fiscal Service of Ukraine № 12969-6-99-99-15-02-02-15 from 10.06.2016

Income from transactional and non-transactional exchange differences is taken into account for the calculation of annual income (50 mln. UAH.) of taxpayer from any activity for the purpose of transfer pricing and is not taken into account for calculating the volume of business transactions (5 mln. UAH.) of taxpayer with each counterparty. More...

2017-07-11T08:37:19+00:00 11.07.17|Cost criterion|

Letter from the State Fiscal Service of Ukraine № 12675/6/99-99-15-02-02-15 from 09.06.2016

The amount of loans granted (received) is not taken into account when determining the value criterion of controlled transactions for the purposes of transfer pricing. At the same time, the amount of accrued interest for such transactions is taken into account when determining the value criterion of controlled transactions. More...

2017-07-11T08:36:11+00:00 11.07.17|Cost criterion|

Letter of the State Fiscal Service of Ukraine № 11811/6/99-99-15-02-02-15 from 31.05.2016

1. In determination of the amount of business transactions of a taxpayer with a non-resident-associated party (UAH 5 million), the volume of transactions for the sale of goods, for which the ownership has been transferred, is taken into account. 2) The return of the purchased goods, which are used in the processing of raw materials, [...]

2017-07-11T08:35:08+00:00 11.07.17|Cost criterion|

Letter of the State Fiscal Service of Ukraine № 11654/6/99-99-15-02-02-15 from 27.05.2016

1)In determination of the volume of taxpayer's business transactions of the export of products on the basis of pre-payment by a non-resident registered in the low tax jurisdiction, the volume of sales of products for which the ownership has been transferred is taken into account. 2) The size of the discount that affects the price [...]

2017-07-11T08:31:42+00:00 11.07.17|Cost criterion|