Transfer pricing

We anticipate and resolve transfer pricing issues for any business with international operations.

Transfer pricing was adopted in Ukraine in 2013. Crowe A&A Ukraine has been providing transfer pricing services for over 10 years.

Professional staff includes more than 100 specialists together with audit practice, including more than 40 certified auditors of Ukraine, ACCA, CAP/CIPA. We provide services having access to the following databases: Refinitiv (Thomson Reuters), Bureau van Dijk databases (TP Catalyst, RUSLANA), RoyaltyRange, and it is possible to access almost all databases through the Crowe Global network, TOP-10 global audit networks.

Our transfer pricing services:

Audit of controlled transactions
Preparation of transfer pricing policies
Transfer pricing documentation (Local File)
Preparation of documentation confirming compliance with the “arm’s length” principle for the purposes of Article 140 of the Tax Code of Ukraine
Report on controlled transactions

Audit of controlled transactions
Preparation of transfer pricing policies
Transfer pricing documentation (Local File)
Preparation of documentation confirming compliance with the “arm’s length” principle for the purposes of Article 140 of the Tax Code of Ukraine
Report on controlled transactions

Crowe Erfolg Ukraine and Crowe Audit and Accounting Ukraine are member firms of Crowe Global network of international auditing companies.

Crowe Global ranked the 8th largest international accounting network in the world.

Crowe Global is a market leader, well-known for providing impeccable quality service, demonstrating the highest standards of work quality and working as one team all over the world.

Crowe Global has been providing professional services for more than 100 years and is recognized as one of the best employers.

The quality of Crowe Erfolg Ukraine services is confirmed by the Crowe Global quality control, the Audit Public Oversight Body of Ukraine (APOB) external audit and good feedback from our clients.

Crowe Erfolg Ukraine’s professional liability is insured for the amount of UAH 50 million.

Crowe Erfolg Ukraine has more than 13 years’ experience in the provision of audit services

The Action Plan on BEPS consists of reports on 15 actions, 8 of which have already been implemented in Ukraine in 2020-2021, namely:

Action 3: disclosure by individuals-residents of Ukraine of participation in the controlled foreign companies (CFC), and the regulations of taxation of such companies;

Action 4: limitation of costs for financial transactions with related parties;

Action 6: prevention of irregularities due to the application of double taxation avoidance agreements;

Action 7: prevention of the artificial avoidance of permanent establishment status;

Action 8-10: improvement of the transfer pricing control;

Action 13: country-by-country reporting guidelines for the international group of companies.

In 2022, the State Tax Service of Ukraine joined the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports. The purpose of joining the CbC Multilateral Agreement is to join Ukraine to the international system of automatic exchange of reports by countries, which has already been joined by more than 90 countries of the world.

Currently, a three-tier approach to transfer pricing documentation has been introduced in Ukraine:

Local File — Transfer pricing documentation in conjunction with the Report on Controlled Transactions and the Notification on Participation in the international group of companies. It is submitted by taxpayers if (1) the total revenue exceeds the equivalent of UAH 150 million and (2) the total amount of transactions with a related party or with “low-tax jurisdictions” or with a “low-tax organizational and legal form” exceeds the equivalent of UAH 10 million;
Global transfer pricing documentation (Master file) – submitted by a taxpayer who is a member of the international group of companies, which annual revenue is equal to or exceeds the equivalent of EUR 50 million.
Country-by-country reporting of the international group of companies – submitted when the total consolidated revenue of the international group of companies, which includes the taxpayer, exceeds the equivalent of EUR 750 million and in certain circumstances.