In accordance with the provisions of the Tax Code of Ukraine in force, the penalty for late submission of transfer pricing report is one level of subsistence minimum for the able-bodied person, established by law as of January 1 of the tax (reporting) year, for each calendar day of late submission of transfer pricing report, but not more than 300 subsistence minimums for an able-bodied person established by law on January 1 of the tax (reporting) year (clause 120.4 of Article 120 of the TCU), and for failure to submit a report – 300 rates of subsistence minimum for the able-bodied person, the statutory January 1 of the tax (reporting) year (p. 120.3 Art. 120 TCU).
The Law of Ukraine dated December 7, 2017 № 2246-VIII “On the State Budget of Ukraine for 2018” determined the amount of the subsistence minimum for an able-bodied person was set as of January 1, 2018 at the level of UAH 1,792.
Thus, in case of late submission of the transfer pricing report for 2018, the penalty may be 1 792 UAH for each calendar day of late submission of the report, but the total amount of the penalty will not exceed 528 600 UAH, and for failure to submit the transfer pricing report for 2018 the penalty can amount to 528 600 UAH.
In the light of the above, it is advisable to take care in advance of the preparation and timely submission of the transfer pricing report.
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