The Ukraine State Fiscal Service recently issued guidance letter 1723/6/99-99-15-02-02-15/IPK on the treatment of transactions between a non-resident and its permanent establishment (PE) in Ukraine as controlled for transfer pricing purposes, as well as the determination of taxable profits.
The letter notes that PEs of non-residents that receive income from a Ukraine source or that perform agency (representative) and other functions related to such non-residents or their founders are treated…