On 26 April 2016, Ukraine's State Fiscal Service (SFS) published Guidance Letter 8806/6/99-99-19-02-02-15, which clarifies the country's rules regarding information sources for transfer pricing purposes. According to the letter, for periods beginning on or after 1 January 2015, both taxpayers and tax authorities may use the following to compare the commercial and financial conditions of controlled transactions to determine the arms length price:
- Any information on comparable uncontrolled tra…