Ruslana Tiutenko,
Consultant of the Transfer Pricing Department
Table of Contents
Transfer Pricing and Penalties
We would like to remind you that taxpayers who conducted controlled operations during 2025 are required to submit a Report on Controlled Operations by October 1, 2026.
Additionally, taxpayers who are members of an International Group of Companies (IGC) and conducted controlled operations in 2025 must also submit a Notification of Participation in an International Group of Companies by October 1, 2026.
Failure to comply with these requirements leads to the emergence of tax differences.
The relevance of Transfer Pricing (TP) issues continues to grow, demanding special attention from taxpayers, as non-compliance with the rules entails the imposition of significant penalties.
Below is the list of penalties effective from January 1, 2025.
To avoid falling under heavy penalties, it is crucial to strictly adhere to the established deadlines for Transfer Pricing reporting and ensure that all supporting documentation is prepared well in advance.
Controlled Foreign Companies: Identification and CFC Reporting
Filing reports on Controlled Foreign Companies (CFCs) is a direct obligation for every resident of Ukraine who holds the status of a “controlling person” in accordance with the Tax Code of Ukraine.
CFC reporting is submitted simultaneously with the tax return:
- Until May 1 — for individuals (along with the Declaration of Property Status and Income);
- Until March 1 — for legal entities (along with the Corporate Income Tax Declaration).
Important to Remember:
Despite the suspension of penalties during the state of martial law (provided that the controlling person fulfills their CFC reporting obligations within six months after the termination or cancellation of martial law), the legal obligation remains in effect. Therefore, we strongly advise against delaying your CFC reporting. It is essential to verify your obligations in advance, prepare the necessary documentation, and, if required, engage professional experts to ensure full compliance.
Ready to prepare your Transfer Pricing documentation?Audit Invest will help: screening of operations with non-residents, CO reports, and a full package of transfer pricing documentation.
