The Transfer Pricing Bill approved during its fir... | KPMG | UA

The Transfer Pricing Bill approved during its first reading

The Transfer Pricing Bill approved during its fir...

On June 20th 2013, the Ukrainian Parliament approved the Transfer Pricing Bill (TP Bill) during its first reading. The TP Bill received votes from 279 deputies, well over the required minimum of 226. It is expected that the TP Bill will be adopted during the second and final reading on July 4th, and becomes effective as of January 1st 2014.


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The TP Bill proposes to extend transfer pricing rules to all transactions of a Ukrainian company with a qualifying company (person), where the value of such transactions in any particular year cumulatively exceeds UAH50M. Transactions with the following qualifying companies (persons) are deemed controlled:


  • transactions with Ukrainian or foreign related parties;
  • transactions with unrelated parties located in foreign low-tax (offshore) jurisdictions.


The TP Bill cancels the eligible 20% deviation from the arm’s length price while offering until the year 2018 certain concessions to businesses operating in the strategic sectors of the Ukrainian economy.


KPMG transfer pricing experts would be delighted to meet with you in person to discuss the potential impact of the new transfer pricing rules on your company’s business.


KPMG has a dedicated transfer pricing team consisting of 6 tax experts. Since the beginning of 2012, the team has successfully completed a number of projects for Russian and international clients. Konstantin Karpushin, head of the Transfer Pricing Group in Ukraine, has more than seven years of experience resolving complex transfer pricing issues, which he gained during his work in Russia and Finland.


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