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Ukraine: Draft legislation to amend transfer pricing rules, adopt interest deduction limitation rules

Legislative proposals to align Ukraine rules with OECD and EU standards

November 3, 2026

Draft Law No. 16035 proposes to align Ukraine’s transfer pricing rules with the provisions of the 2022 OECD Transfer Pricing Guidelines, Actions 8–10 of the BEPS Action Plan, and the OECD Council Recommendation on the Determination of Transfer Pricing between Associated Enterprises (OECD/LEGAL/0279).

In addition, the Ministry of Finance on October 6, 2026, announced that a parliamentary committee recommended adoption of Bill No. 16036, which would introduce new interest deduction limitation rules in line with the EU Anti-Tax Avoidance Directive (ATAD). The rules would generally limit the deductibility of borrowing costs to 30% of earnings before interest, taxes, depreciation, and amortization (EBITDA) or a monetary threshold and would apply from January 1, 2028.


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

Oksana Olekhova | oolekhova@kpmg.ua

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