We offer a range of professional
services to reduce tax risks
in transfer pricing
Kreston Ukraine offers a comprehensive approach to managing tax risks related to transfer pricing, including for multinational groups of companies. We prepare transfer pricing reports and documentation in compliance with tax authority requirements, provide advisory services on the business purpose of transactions, and support clients during tax audits and disputes.
In addition, we assist owners of controlled foreign companies (CFCs) with the preparation of CFC reporting, ensuring effective tax risk management and compliance with Ukrainian legislation.
The critical national law on transfer pricing is the Tax Code of Ukraine, Article 39. The international TP rules are represented by the OECD (Organization for Economic Cooperation and Development) Guidelines on Transfer Pricing for Transnational Corporations and Tax Authorities and the requirements of the Plan for Combating Tax Base Erosion and Profit Shifting (BEPS Plan).
Criteria for transfer pricing application:
TP in Ukraine covers exclusively foreign economic activities of a tax payer.
According to Article 39 of the Tax Code of Ukraine, controlled transactions require simultaneous compliance with three criteria (except for representative offices of foreign economic entities in Ukraine):
- the annual income of a tax payer in Ukraine from any activity amounts to more than UAH 150 million;
- during the reporting year, the taxpayer carried out business transactions with non-residents specified in sub-clause 39.2.1.1 of the TCU and sub-clause 39.2.1.5 of the TCU that affect or may affect the financial performance of a company (for example, with related parties, non-resident commission agents, counterparties from the lists specified by the Resolutions of the Cabinet of Ministers of Ukraine №1045 dated 27 December and №480 dated 4 July 2017);
- the volume of transactions with the above-mentioned counterparties, measured by means of the accounting rules, exceeds UAH 10 million for the reporting period.
A Ukrainian enterprise subject to transfer pricing (according to Article 39 of the TCU) shall submit to the supervisory authority by October 01 of the year following the reporting year:
- Report on Controlled Transaction;
- Notification of participation in an International Group of Companies (in case of joining such an IGC).
In addition, it is necessary to prepare TP Documentation and, in some cases, a Master File and a Country-by-Country Report.
WHAT WILL YOU GET:
PRACTICE LEADERS
TRUSTED BY THE BEST
Permanent communication with representatives of UKRPOSHTA allowed the company's consultants to find the optimal solution for the implementation of the agreed project and check the presence of transfer pricing risks. Considering the positive experience of cooperation, we recommend Kreston Ukraine as a reliable and competent partner in the field of transfer pricing.
UKRPOSHTA
The results of cooperation allow us to conclude that Kreston Ukraine experts are true professionals in their field. We are satisfied with the result and are ready to expand our partnership in the future. We recommend Kreston Ukraine as a reliable consultant and experienced transfer pricing expert.
SCHROEDER UKRAINE
Pharmastor LLC has been cooperating with Kreston Ukraine since 2017 and has no doubts about the high qualifications and competence of the specialists in this company. Through many years of cooperation, we have become convinced of the integrity, objectivity and professionalism of Kreston Ukraine employees. In view of many years of positive experience of cooperation, Pharmastor confidently recommends Kreston Ukraine as a reliable, competent and highly qualified partner in the field of transfer pricing.
PHARMASTOR
The extremely attentive attitude of Kreston Ukraine specialists to the needs of the client, the ability to quickly navigate and find solutions to problems should be noted, as well as excellent knowledge of tax legislation. The internal and external communication of the team is also commendable. We are completely satisfied with the quality and efficiency of company’s work and recommend Kreston Ukraine to resolve tax issues and provide transfer pricing services.
FC "DYNAMO KYIV"
The quality of services provided to us by Kreston Ukraine team meets our high expectations from working with a company that has a reputable international network. The experts helped us to find a convincing justification for our arm's-length operations and carefully prepared all the necessary documentation stipulated by the terms of the contract. The team of experts is distinguished by deep competence and understanding of the specific features of the banking sector. We are satisfied with our cooperation with Kreston Ukraine and confidently recommend the company to everyone who needs help with transfer pricing issues.
BANK FOR INVESTMENTS AND SAVINGS
Kreston Ukraine specialists provided our company with transfer pricing services. In the course of the work, the company's specialists prepared recommendations that made it possible to significantly improve the quality of our transfer pricing documentation. Since cooperation with Kreston Ukraine has fully justified itself, Budpostach confidently recommends the experts of this company to resolve issues and consultations on transfer pricing.
BUDPOSTACH
During the period of cooperation, the employees of the company have established themselves as specialists who fulfill their obligations at a high quality level and strictly within the terms established by the contract. We note the efficient work and promptness of tasks, attentive attitude to the needs of the client and deep knowledge of the industry.
STAR MEDIA
We are satisfied with our cooperation with Kreston Ukraine and recommend the company as a reliable business partner. The team carried out high-quality work and data analysis, focusing on the main transfer pricing rule - the “arm's length” principle. All information was provided within the terms established by the contract.
ROSHEN
In the course of work, we were convinced of the high qualifications of Kreston Ukraine employees. The specialists quickly responded to the questions we had during the project implementation. The company has extensive experience not only in the field of transfer pricing, but also in the taxation of agricultural enterprises in Ukraine.
MAS SIDS UKRAINE
The services provided by Kreston Ukraine allowed us to fulfill our obligations under Art. 39 and Art. 140.5 of the Tax Code of Ukraine. Our experience of cooperation was positive; therefore, we confidently recommend Kreston Ukraine as a competent expert in the field of transfer pricing.
UNIVERSAL FISH COMPANY
Specialists have demonstrated the ability to carefully and timely perform all necessary procedures and adhere to the conditions specified in the contract. Attention and flawless communication between the team and the client deserve recognition. The company fulfilled all contractual obligations in full.
MONOMAKH
