Letter of the State Fiscal Service of Ukraine №1233/6/99-99-15-02-02-15 dd 17.07.2017

Business transaction of free provision of goods falls under the definition of controlled transaction if the recipient of a non-repayable goods is a related non-resident party. Thereby, the price of such goods for transfer pricing purposes is taken into account considering the conditions of all contracts related to this transaction, which may affect the object of taxation of income tax for the resident.

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