Ukraine's State Fiscal Service (SFS) recently published guidance letter 27432/6/99-99-19-02-02-15, which covers the reporting and transfer pricing documentation requirements for controlled transactions. Under Ukraine's transfer pricing rules, which were amended 15 July 2015 ({News-2015-07-29/A/2- previous coverage}), transactions are deemed controlled for transfer pricing purposes when:
- The taxpayer's annual income exceeds UAH 50 million; and
- The value of the annual transactions with a rela…