Ukraine's State Fiscal Service recently issued guidance clarifying that in determining if income/transaction thresholds are met for transfer pricing purposes, income arising from operational and non-operational foreign exchange differences are to be included. Under Ukraine's amended transfer pricing rules, adopted 15 July 2015 ({News-2015-07-29/A/2- previous coverage}), transactions are recognized as controlled when:
- The taxpayer's annual income exceeds UAH 50 million, and
- The value of the a…