The Ukraine State Fiscal Service (SFS) recently published guidance letter 29/6/99-99-15-02-02-15 concerning taxpayer transfer pricing adjustments. According to the letter, taxable income from controlled transactions involving non-residents is to be adjusted on an annual basis with the taxpayer's financial result for the year increased by:
- The amount by which the arm's length price exceeds the contract price for goods, works, or services sold in controlled transactions;
- The amount by which t…