The transfer pricing policy may include the development of Three-Level Documentation for international groups of companies, which became mandatory in Ukraine from the 2020 reporting year after the relevant changes were made to the Tax Code of Ukraine:
– Local File (TP Documentation for Ukraine),
– Master File (Global TP Documentation),
– Country-by-Country Report (CbCR).
The structure of TP reporting for participants of international groups is as follows:
Failure to submit a Notification of participation in an IGC or provision of inaccurate information therein is subject to a fine of 50 subsistence minimums for an able-bodied person (SMAP). The fine amount for the 2024 reporting year is UAH 3,028 x 50 = UAH 151,400.
Failure to submit the Master File is subject to a fine of 300 SMAP, i.e., for the 2024 reporting year, the penalty is UAH 3,028 x 300 = UAH 908,400.
Failure to submit the CbCR is subject to the most significant penalty: 1,000 SMAP; for the 2024 reporting year, it is UAH 3,028,000. The application of sanctions for non-submission of the Country-by-Country Report has already become possible because on November 3, 2022, Ukraine joined the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports, or CbC Multilateral Agreement.
ШТРАФИ ЗА НЕПОДАННЯ ТРИРІВНЕВОЇ ДОКУМЕНТАЦІЇ:
Kreston experts in Ukraine have extensive experience in tax consulting, preparing reports and Three-Level Documentation by the current norms of national and international legislation.
