Ukraine MOF Announces Bill to Amend Transfer Pricing Provisions

The Ukrainian Ministry of Finance Feb. 24 announced a bill to amend transfer pricing provisions in accordance with EU standards, the 2022 OECD Transfer Pricing Guidelines, and Actions 8 through 10 of the Base Erosion and Profit Shifting (BEPS) Action Plan. The bill includes measures to: 1) revise the threshold for recognizing transactions as controlled; 2) extend the arm’s length principle to certain domestic transactions with loss-making enterprises and entities using preferential tax regimes; 3) clarify the controlled transaction algorithm for comparability analyses, and the application of transfer pricing methods; 4) modify the approach for transactions with intangible assets; and ...