Letter of the State Fiscal Service of Ukraine №6611/6/99-99-15-02-02-15 from 31.03.2017

The requirements of Article 140.5 of the Tax Code of Ukraine to increase the financial result for the amount of royalties may not apply if the amount of the royalty is confirmed in accordance with the procedure established by the transfer pricing rules. Since the value criterion of controlled transactions are set on a yearly [...]

Letter of the State Fiscal Service of Ukraine № 11655/6/99-99-15-02-02-15 from 27.05.2016

If the taxpayer does not adjust the financial result before tax during execution of uncontrolled transactions with non-residents registered in low tax jurisdictions, exercising the right provided by item 140.5 of Article 140 of the Tax Code of Ukraine, and the amount of expenses is confirmed by the payer under the rules of normal prices [...]

Letter of the State Fiscal Service of Ukraine № 1555/6/99-99-19-02-02-15 from 27.01.2016

If an entity makes payments that, according to the rules of accounting, are recognized as royalties and are included in expenses, and for the purpose of taxation such payments do not fall under the definition of royalties, the enterprise does not form a difference for adjusting the financial result before taxation. More...

Letter of the State Fiscal Service of Ukraine № 18915/6/99-99-19-02-02-15 from 04.09.2015

Transactions with a non-resident independent party are not recognized as being controlled if he is not registered in the low tax jurisdiction, regardless of whether the participant of such non-resident is a resident of the state included in the list. Also, paragraph 140.5 of Article 140 of The Tax Code of Ukraine is not applied [...]