Businesses continue to grow and evolve in today’s complex global and digital environment. The public demands more transparency on tax issues related business operations, while governments and tax authorities are increasingly stringent when it comes to businesses’ compliance with transfer pricing (TP) legislation. This all means that a solid TP policy and structure are now integral internal compliance requirements for any business entity.

KPMG in Ukraine’s TP solutions are sustainable and compliant with both international and Ukrainian tax regulations. Our approach focuses on your business’ broader commercial objectives, helping our clients to develop and form TP policies, conduct comparative studies, and document their controlled transactions in compliance with the latest OECD Guidelines and the Tax Code of Ukraine. Moreover, KPMG in Ukraine provides your business with value chain management analysis, assistance in resolving disputes with tax authorities, and transfer pricing issue advice.

KPMG in Ukraine’s transfer pricing team has all the resources and experience to provide you with the level of quality and attention to detail that a modern business demands. We have assembled the largest TP team in Ukraine, with more than 30 professionals working at KPMG in Ukraine.

Who needs TP services?

  • Corporate income taxpayers that conduct transactions with non-residents
  • The company under tax payers control
  • Representative offices of non-residents subject to corporate income tax

What risks do companies face?

  • Need to adjust income tax base in case prices / profitability are found to be non-compliant with the arm's length principle for transactions subject to TP control
  • So-called "constructive dividends" being charged with additional withholding tax
  • Late or incomplete reporting related to controlled transactions

How can we help? Services of KPMG Transfer Pricing Group in Ukraine:

  • General advice on transfer pricing issues
  • Controlled transaction identification
  • Controlled transaction report preparation and notification of participation in an international group of companies
  • Transfer pricing documentation preparation and updates
  • Assistance concluding advance pricing agreements (APAs)
  • Transfer pricing policy development and implementation
  • Value Chain Analysis
  • Preparation of official justification for non-application of 30% financial difference as per Article 140.5.  of the Tax Code of Ukraine regarding uncontrolled transactions
  • Group master file preparation / adaptation
  • Preparation of the Country-by-Country Report (CbCr)
  • Analysis of ‘reasonable economic purpose (business aim)’ existence

Why KPMG in Ukraine?

Large team

The biggest tax professional team in Ukraine. You can always count on our team to devote as much time and attention as you need to get the job done.

Required experience

We have repeatedly solved similar issues for other companies in various industries, and our contractual record and client feedback are a testament to our success.

"Fiscal" approach

We analyse each situation from the perspective of international and Ukrainian tax authorities because we know that the tax authority that is the ultimate recipient of any documentation.

Time efficiency

Well-established internal business processes and our extensive team enable KPMG in Ukraine to solve issues quickly and efficiently. Your project manager is available to you at any time.

Process automation

We use KPMG software systems that enable us to eliminate the "human factor", use the results and our experience gained in other work to benefit all our clients, and conduct in-depth financial and statistical analyses.


We approach our work from the perspective assumed by the regulatory authorities and courts to best support your company during tax inspections and thoroughly identify any potential risks.

Period of limitation

We guarantee documentation maintenance during the mandatory 7-year limitation period wherein tax authorities can review and return to tax investigations. KPMG as a legal entity and your relevant TP team will always be available to serve our clients.

Data processing

We help download data from SAP, 1C, and Microsoft Navision accounting systems as necessary and upon the separate request of the client.