The Ukraine State Fiscal Service (SFS) recently published guidance letter No. 5898/7/99-99-14-01-02-17 concerning the treatment of a capital contribution of fixed assets as controlled for transfer pricing purposes. The letter notes that one of the conditions for a transaction to be deemed controlled is that the transaction impacts the taxation of the taxpayer. While the contribution (increase in capital) itself does not impact taxation, the subsequent depreciation of the fixed assets does, a…