On 17 July 2015, the Ukrainian government issued Decree 504, which sets out the procedures for concluding advanced pricing agreements (APA). The Decree allows for unilateral, bilateral or multilateral APAs. It entered into force on 24 July 2015.
Preliminary Examination
To begin the APA process, the taxpayer may submit a request for a preliminary examination of the relevant transaction to the State Fiscal Service (SFS). The SFS must then respond within 60 days as to whether it would be reas…