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New Procedures for Documenting Transfer Pricing Assessments
On 31 December 2009 the State Tax Administration of Ukraine introduced a procedure for the preparation of court submissions of transfer pricing adjustments. Taxand Ukraine discusses the new procedure and why this is a step towards the enforcement of transfer pricing rules.
Under the new guidelines the State Tax Administration has set out essential steps for tax authorities to take when documenting and recording transfer pricing assessments. Assessments must then be submitted to the tax authorities' legal departments for the subsequent preparation for an application to the court. The impact of these new guidelines is still unknown and we'll need to time understand how they will be applied going forward.
Legislation and development of these new procedures should be closely monitored as the State Tax Administration of Ukraine views transfer pricing rules as a key priority. To date, there is limited court practice relating to transfer pricing assessments so staying apprised of progress will be important in understanding its significance going forward.
Your Taxand contact for further queries is:
Vladimir Volodymyrska St.
T. +380 44 492 8282
Read the full announcement from Taxand Ukraine here: