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Starting from 1 January 2022, an individual resident of Ukraine or a legal entity resident of Ukraine is obliged to notify the supervisory authority of – each direct or indirect acquisition of a share in a foreign legal entity or the beginning of the exercise of actual control over a foreign legal entity, which leads …
Controlled foreign companies and Controlling person
On January 01, 2022, Law No. 466-IX of January 16, 2020, which amended the Tax Code of Ukraine and introduced the institution of a controlled foreign company, came into force. Also, Article 392 was supplemented to introduce the concept of a controlled foreign company (CFC).A controlled foreign company is any legal entity registered in a …
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Implementation of functional analysis of transfer pricing
In this section we will analyze what functional analysis is, what are the functions and why it is necessary What does functional analysis mean? In accordance with the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, Function, Assets and Risk (‘FAR’) Analysis is defined as an analysis of the functions performed (taking into …
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Preparation of Global transfer pricing documentation
It should be reminded that in 2021, the changes in the field of transfer pricing voted by the Verkhovna Rada of Ukraine according to the Law No. 466-IX (№1210) came into force – according to which Ukrainian companies will prepare Global Transfer Pricing documentation (master file). For whom is the preparation of the master file …
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Top issues of transfer pricing in 2019
Top issues of transfer pricing in 2019 Transfer pricing – is a control of prices in transactions between tax payers and related non-residents, or counterparties from low tax jurisdictions, according to the criteria of the country of registration or the organizational form of counterparty. For whom the transfer pricing is relevant: 1. Ukrainian tax payers …
From 1 January 2019, many of Ukrainian companies are required to switch to IFRS.
From 1 January 2019, many of Ukrainian companies are required to switch to IFRS. What are the difficulties related to transition to IFRS: From 1 January 2019, many of Ukrainian companies are required to switch to IFRS. What to expect from transformation? How can a transition affect your company? Highlights: Transition to IFRS means that …
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