According to Article 39 of the Tax Code of Ukraine (TCU), the Ukrainian enterprise subject to transfer pricing shall submit to the supervisory authority by October 1 of the year following the reporting year:
In addition, it is necessary to prepare TP Documentation and, in some cases, a Master File and Country-by-Country Report (CbCR).
Report on Controlled Transactions, Notification of participation in an IGC and CbCR are submitted to the regulatory authorities in electronic form by the form approved by the Ministry of Finance.
Transfer Pricing Documentation is prepared either at the same time as the Report (preferably) or later. Its content is regulated by sub-clause 39.4.6 of the TCU, in particular, but not exclusively:
Penalties provided for by the tax laws for the reporting year 2024:
300 subsistence minimum for an able-bodied person (SMAB), namely UAH 3,028 x 300 = UAH 908,400.
therein is subject to a fine of 50 SMAB, i.e. UAH 3,028 x 50 = UAH 151,400.
(but not more than 200 SMAB), namely UAH 3,028 x 200 = UAH 605,600.
a penalty will be charged for such non-submission for UAH 3,028 /6,056 for each day of the delay in submission of the report/documentation.
