As of 25 March 2025, amendments to the Tax Code of Ukraine regarding penalties for violations of transfer pricing reporting requirements come into force.
The key changes include:
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Failure to submit a notification on participation in a multinational enterprise group (MNE Group) — the penalty has been increased from 50 to 100 subsistence minimums for an able-bodied person as of 1 January of the reporting year (for FY 2024 — UAH 302,800).
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Late submission of the MNE Group participation notification — the penalty has been reduced from 100 to 50 subsistence minimums (for FY 2024 — UAH 151,400).
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Late declaration of controlled transactions in the transfer pricing report (when submitting an amended report) — a penalty of one subsistence minimum per day of delay applies, capped at 300 subsistence minimums or 0.5% of the undeclared transaction value (the lower amount applies).
It is important to note that penalties imposed as a result of tax audits are applied at the rates effective as of the date the relevant decision is made.
In light of these changes, taxpayers are advised to ensure the timely submission of the notification on participation in an MNE Group in order to avoid significant financial exposure.
