Ukraine: Consultation on proposed amendments to transfer pricing rules, introduction of interest deduction limitation and hybrid mismatch provisions

Proposed transfer pricing amendments would align rules with EU and OECD standards.

The Ministry of Finance on February 24, 2026, launched a public consultation on a draft law proposing amendments to the transfer pricing rules that would apply from January 1, 2028.

The draft law would align domestic transfer pricing provisions with EU standards, the 2022 OECD Transfer Pricing Guidelines, and BEPS Actions 8-10.
Key proposals include revised thresholds for controlled transactions, broader application of the arm’s length principle to certain domestic transactions, clarification of transfer pricing methods and DEMPE analysis for intangibles, and a redesigned penalty framework to encourage voluntary compliance.
The proposal would also simplify transfer pricing documentation and reporting, including reduced documentation requirements for taxpayers with annual income up to UAH 150 million and controlled transactions up to UAH 10 million.

The Ministry of Finance also launched a public consultation on a draft law proposing the implementation of selected measures from the EU Anti‑Tax Avoidance Directive (ATAD 1 and 2). The proposal would introduce an interest deduction limitation based on 30% of EBITDA, exit taxation rules, a general anti‑abuse rule, and hybrid mismatch provisions.

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

Oksana Olekhova | oolekhova@kpmg.ua

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Ukraine: Consultation on proposed amendments to transfer pricing rules, introduction of interest deduction limitation and hybrid mismatch provisions

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