Letter of the State Fiscal Service of Ukraine № 1517/6/99-99-15-02-02-15 dd 07.08.2015

If the comparison of prices or profitability in a controlled transaction is carried out with prices or profitability indicators of two or more comparable uncontrolled transactions or legal entities that do not deal with related parties, the price range (profitability) has to be used. If the number of comparable uncontrolled transactions or legal entities that do not deal with related parties is only one, then the price range (profitability) for transfer pricing purposes is not used.

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