Letter of the State Fiscal Service of Ukraine № 9015/6/99-99-15-02-02-15 from 26.04.2017

Payments in the form of royalties are accounted as expenses and affect the formation of the object of income tax taxation. Such transactions are recognized as controlled, regardless of the fact in which of the periods (reporting or subsequent) this effect occurs.
Such transactions should be reflected in the Report on Controlled Transactions in the reporting period in which the business transaction of receiving (paying) royalties has occurred, regardless of the decision of the taxpayer either to display or not to display such royalties as part of the expenses in the income tax declaration.