Transfer pricing (TP) allows set prices to differ from market prices due to tax optimization. Reducing tax expenses affects the increase in profits.
Transfer Pricing raises many issues. Our team provides a professional solution to them, considering all the nuances related to your company’s business and legal regulations.
We offer:
Contact the experts to ensure the work is done well and all requirements are met!
Multilingual Service: We offer services in four languages: Ukrainian, English, Polish, and Russian. This capability ensures seamless communication without the need for an interpreter, allowing us to truly understand our clients on every level.
Direct Involvement of the Managing Partner: We take pride in our professionalism and reputation. Our commitment goes beyond mere words; we genuinely respect our clients and always seek a personalized approach. Every client receives our undivided attention.
Holistic Business Perspective: Our expertise spans three distinct areas: auditing, forensic analysis, and appraisal. This comprehensive skill set enables us to delve deep into issues, considering nuances that only specialists in specific fields are aware of.
Over 30 Years of Experience: Annually, we collaborate closely with at least ten companies, offering them complete support. Additionally, we assist numerous other businesses in addressing specific challenges, ensuring every client achieves their desired outcome.
Client-Centric Approach: We prioritize understanding and meeting your needs. We keep you informed about the progress of our work and guarantee confidentiality, punctuality, and precision in our services.
Adaptability and Efficiency: We stay updated with evolving TP legislative requirements and processes. By leveraging modern software, we ensure our work is both automated and optimized, enhancing the speed and accuracy of our services.
When you engage with our team, you can expect:
Policy Execution: We’ll design and assist in rolling out an effective Transfer Pricing (TP) strategy tailored for your business.
Transparent Work Framework: We provide a step-by-step action plan focused on tax optimization. We’ll tackle the intricate matters and guide you on how to address them.
Assurances: We aim to reduce business risks and enhance operational efficiency, all while ensuring utmost confidentiality.
Dedicated Support: Count on us for assistance in drafting documentation and reports, and for expert guidance during audits and in resolving any TP-related challenges.
While the term itself might not seem daunting, the repercussions for taxpayers who violate the reporting rules for controlled transactions, as outlined in the Tax Code, can be severe.
Consider this: a penalty of 300 PM or 681,000 hryvnias for not submitting a report on controlled transactions for 2021 is a substantial amount for any business (as per paragraph 3 of clause 120.3 of the Tax Code). There are also penalties for not notifying about membership in an international group and for not providing documentation within the stipulated time frame upon request.
In the current business landscape, it’s possible that as your enterprise taps into untapped markets, it starts to grow rapidly. Before you know it, you might find your business in a completely different league.
Let’s Clarify the Details
With the incorporation of transfer pricing and controlled transaction regulations into the Tax Code, taxpayers are now tasked not only with the preparation of reports on controlled transactions and transfer documentation but also with addressing inquiries from tax authorities. These inquiries are formulated based on the Procedure sanctioned by the Order of the Ministry of Finance No. 706, dated August 14, 2015.
Frequent Questions Posed by Tax Authorities on Controlled Transactions Include:
Sources of Information for Tax Authorities’ Analysis and Monitoring:
Furthermore, on November 3, 2022, Ukraine became a signatory to the Multilateral Agreement of Competent Authorities on the Automatic Exchange of Country Reports (CbCR MCAA). This means that, in addition to utilizing its indigenous information systems and software tools, the national tax service will now have access to data on the operations of international corporate groups. This will inevitably broaden the scope of questions they pose to taxpayers.
With the introduction of norms regarding transfer pricing and controlled transactions in the Tax Code, taxpayers are faced not only with the need to prepare reports on controlled transactions and transfer documentation but also with the need to respond to inquiries from the tax service.
When preparing such inquiries, the controlling body follows the Procedure approved by the order of the Ministry of Finance dated August 14, 2015, No. 706.
The most common questions in tax inquiries regarding controlled operations are:
Sources from which tax authorities obtain information for analysis and monitoring:
Moreover, as of November 3, 2022, Ukraine joined the Multilateral Competent Authority Agreement on Automatic Exchange of Country-by-Country Reports (CbCR MCAA). In addition to its own information systems and software products, the country’s tax service will receive information about the activities of international corporate groups and, of course, will be able to expand the list of its questions to taxpayers.
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Our team of tax consultants provides transfer pricing services for businesses in Ukraine. We ensure the preparation of a complete set of documents, the drafting of reports on controlled operations, and the development of an individual transfer pricing policy for your company.
We describe the activities of our client and the group of companies they belong to by conducting a comprehensive analysis of their financial and economic operations.
In preparing the Transfer Pricing Documentation, we conduct a comprehensive analysis of documents related to transactions carried out between associated parties.
We conduct an analysis of the company's field of activity, competitive environment, volume and dynamics of sales, as well as the geographical distribution of the company's operations.
We employ a systematic approach that encompasses the selection of transfer pricing methods, the preparation of Documentation, and the Report on Controlled Operations.
Our team is in touch. You can ask a question through the form or get answers by phone.
Both options are possible. Any service is independent and can be provided both separately and with other services. Comprehensive service or ongoing support is formed individually at your request.
An accountant is a therapist, and we are cardiologists. That is, our team specializes in a narrower and more specific area, dealing specifically with TP issues.
Without additional training, an accountant is not competent in this area. There is still a risk of making a mistake, which can even lead to a fine or a lawsuit.
The term depends on the scope and complexity of the task. We discuss this personally at the first stages of communication with the client.
The cost is agreed upon separately for each customer. Use the calculator on our website to calculate it.
