Substantiation of transfer prices

Pro-Consulting along with our partners, the leading Ukrainian auditing company, has developed a set of services to regulate the company's pricing policy in accordance with the current legislation regarding transfer pricing.


What is transfer pricing?

Transfer pricing is the tracking of prices in transactions with related companies, as well as with legal entities registered in offshore zones. The idea of ​​the TP is that prices should be commensurate with market prices as if independent companies were making a similar transaction.

Which operations are regulated with the TP?

Companies, transactions with which are subject to control of the TP, should be:

  • Related and registered abroad
  • Contractors registered in the same country, but showing consistently negative financial results or having benefits granted by the tax service.
  • Registered in jurisdictions with low taxation.

When are such operations a subject to control?

Transactions with the companies mentioned above are under the control of the tax authorities in excess of the total turnover of over UAH 50 million. The Tax Code of Ukraine has established acceptable methodologies and sources of incoming data used in determining the usual (market) price.

What is the threat of violation of the rules for conducting such operations?

  • Accrual of tax liabilities
  • Penalties from controlling authorities
  • Additional unplanned inspections by the tax service.

How can we help?

Specialists of our company and a partner of Pro-Consulting, the leading audit company of Ukraine, conduct the analysis of the performed operations. As a result, you receive recommendations allowing to avoid fines and inspections. The list of our services for the analysis of the company's transactions includes:

  • Stocktake of operations controlled by the TP legislation;
  • Calculation and justification of transfer prices that are acceptable under current legislation;
  • Provision of transaction reports;
  • Preparation of documentation for TP;
  • Development of pricing policy that meets the requirements;
  • Consultations on risk management related to taxation of controlled transactions;
  • Consultations on conducting transactions that are subject to control;
  • Consultations on the distribution of profits between the main company and counterparties that are subject to the control of the TP;
  • Consulting on automation of reporting and price control;
  • Analytical and consulting support in communication with tax authorities;
  • Training of specialists in transfer pricing

To order market analysis or another services, or to purchase a published project, please contact us via or +38 (044) 233-34-32

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