The Ministry of Revenue & Duties’ updates
The first accounting period to be audited upon reports on controlled transactions submitted by taxpayers will be 2013. To determine a scope of controlled operations it is required to take into account an aggregated qualitative index per counteragent in total, for a calendar year. Thus, the report for 2013 submitted by a taxpayer should show controlled operations starting from September 1 to December 31, 2013. This report should be filed no later than October 1, 2014, the website of the Ministry of Revenue & Duties says.
It is worth noting that Law of Ukraine adopted on July 04, 2013, №408 on changes to the tax code of Ukraine as regards transfer pricing, which is used to determine the first accounting reference period for filing reports on controlled operations, came into force on September 1, 2013.
These requirements along with some other instructions are set out in the general fiscal guidance detailing how to apply particular rules and norms of tax legislation on transfer pricing. On 01.07.2014 the Ministry of Revenue & Duties of Ukraine adopted resolution № 368 that is entering changes to the general fiscal guidance, more precisely tackling an issue of some norms of fiscal legislation on transfer pricing approved by the MRD on 22.11.2013, resolution №699.
