Letter of the State Fiscal Service of Ukraine № 243/6/99-99-15-02-02-15 from 18.05.2017

Business transactions of a taxpayer with a non-resident associated party completed after country's withdrawal from the List of Low Taxes Jurisdictions may be used to determine the conformity of the controlled transaction conditions to the "arm's length" principle, taking into account the requirements for the comparability of the commercial and financial conditions of abovementioned transactions [...]

2017-07-11T08:14:27+00:00 11.07.17|Information sources|

Letter of the State Fiscal Service of Ukraine № 11132/6/99-99-15-02-02-15 from 23.05.2016

1) Investments received in cash are not included in the determination of the value criterion of controlled transactions for the purposes of transfer pricing. At the same time the amount of investments received in a different form, as well as the amount of paid royalties is taken into account when calculating the value criterion. 2) [...]

2017-07-11T08:11:08+00:00 11.07.17|Information sources|