For the first time, the STS requests to taxpayers to submit global transfer pricing documentation (master file) are applied for the fiscal year ending in 2021.
According to clause 39.4.7 of the TCU, the central executive authority implementing the state tax policy shall have the right to send a request with the requirement to provide global transfer pricing documentation (master file) to a taxpayer who is part of an international group of companies, if the total consolidated income of the international group of companies for the financial year preceding the reporting year, calculated according to accounting standards applied by the parent company of the international group of companies, is equal to or exceeds the equivalent of EUR 50 million rubles.
A request for submission of global documentation (master file) may be sent no earlier than twelve months and no later than thirty-six months from the end date of the financial year established by the international group of companies to which such taxpayer belongs, and in the absence of information about the financial year established by the international group of companies – no earlier than twelve months and no later than thirty-six months after the end of the reporting year.
Global transfer pricing documentation (master file) must be submitted by the taxpayer to the central executive authority implementing the state tax policy within 90 calendar days from the date of receipt of the request.
If two or more taxpayers who are part of the same international group of companies are registered in Ukraine, the central executive authority implementing the state tax policy shall send a request for the provision of global transfer pricing documentation (master file) to only one of these taxpayers of their choice.
For the first time, supervisory authorities’ requests to taxpayers to submit global transfer pricing documentation (master file) are applied for the fiscal year ending in 2021 (clause 53, Subsection 10, Section XX of the TCU).