Ukraine: Updates to scope of “controlled transactions” for transfer pricing purposes

Updated list of low-tax jurisdictions, transactions with permanent establishment in Ukraine of Austrian limited partnership

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February 19, 2025

The Cabinet of Ministers updated the list of low-tax jurisdictions—transactions with counterparties from which will be treated as "controlled transactions" for transfer pricing purposes effective January 1, 2025—to now include 46 states and territories (compared to 78 states and territories on prior list).

The State Tax Service (STS) clarified that a rental transaction between a Ukrainian resident and a permanent establishment (PE) in Ukraine of an Austrian resident limited partnership qualifies as a controlled transaction for transfer pricing purposes if the Ukrainian taxpayer's annual turnover exceeds UAH 150 million and the transaction value with the PE surpasses UAH 10 million. The grounds for the classification is that the Austrian limited partnership is included in the Ukrainian list of legal forms of nonresidents that do not pay the corporate income tax in Ukraine.


For more information, contact a KPMG tax professional in Ukraine:

Oksana Olekhova | oolekhova@kpmg.ua

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