Letter of the State Fiscal Service of Ukraine № 11233/6/99-99-15-02-02-15 from 24.05.2016

Transactions executed in 2014 with a non-resident, an independent party who is registered in a state not included in the List of Low Taxes Jurisdictions, fall under the definition of controlled if such a non-resident pays a corporate income tax at a rate of 5 and more percentage points lower than in Ukraine. At the [...]

Letter of the State Fiscal Service of Ukraine № 10067/6/99-99-15-02-02-15 from 05.05.2016

Business transactions with a party having a tax address in the territory of the Free Economic Zone "Crimea" may be recognized as controlled if such party is associated to the taxpayer or if such party is a commissioner in foreign economic transactions for the sale of goods, subject to the achievement of the value criterion. [...]

Letter of the State Fiscal Service of Ukraine № 13362/7/99-99-19-02-02-17 from 14.04.2016

1) In order to recognize transactions performed in 2015 as controlled, it is necessary to simultaneously fulfill the following conditions regarding the cost criterion: - the annual income of the taxpayer from any activity exceeds 50 million UAH; - the volume of such business transactions of the taxpayer with each counterparty exceeds UAH 5 million. [...]

Letter of the State Fiscal Service of Ukraine № 2716/6/99-99-19-02-02-15 from 10.02.2016

1) 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. 2) If [...]

Letter of the State Fiscal Service of Ukraine № 23389/10/28-10-06-11 from 21.10.2015

The transactions of the taxpayer on the sale of goods to a non-resident registered in the low tax jurisdiction through a commissioner are recognized as controllable if the value criterion are fulfilled, since the right of ownership of the goods transfers directly from the taxpayer to the non-resident purchaser. More...