The Ukraine State Fiscal Service has published guidance letter No. 9012/6/99-99-15-02-02-15 concerning transactions between two parties when the parties are controlled by a third party. The letter clarifies that for the purpose of the transfer pricing rules, a resident entity and non-resident entity will be deemed related when a third non-resident (or resident) entity separately owns corporate rights of 20% or more in each entity. In such case, transactions between the resident and non-resid…