On 30 January 2018, KPMG experts conducted the workshop “Transfer pricing in 2018. Innovative evidence: how to get successful protection in court?”, the second transfer-pricing workshop as part of a series of workshops in Liga.
Larysa Antoshchuk, Head of Tax Dispute Resolution Group, KPMG Law Ukraine, and Yevgeniya Marushchenko, Senior Consultant, Transfer Pricing Group, KPMG in Ukraine, spoke to representatives of various businesses.
“The workshop concept allows a 100% realization of educational component, therefore, this time we covered a
wide range of issues related to the first TP legal precedent, specifics of judicial protection and generation of evidential basis, challenging decision notices on penalties to be paid for failure to submit controlled transaction
reports, and other practical issues that would help businesses avoid TP litigations”, Larysa Antoshchuk said.
Natalia Musiyenko and Roman Gerasymenko, legal specialists, Tax Dispute Resolution Group, KPMG Law Ukraine, analyzed details of several litigation cases involving workshop attendees.
Yevgeniya Marushchenko started her presentation with changes in legislation and presented detailed analysis of
correct reporting issues including monitoring of controlled transaction terms and types of TP adjustments, as well as spoke on the most interesting aspect – projections of TP audits in 2018.
“Such issues as tax compliance, tax control, and challenging tax authorities’ actions / omissions to act and
decisions are always on the edge of business’s and fiscal authorities’ interests, especially when TP issues are involved, that are “more expensive” for business in terms of penalties and “more lengthy”, since period of limitation and period of retention of TP related documents are increased to 7 years”, Yevgeniya Marushchenko summarized the key subject matter of the workshop.