Levelling of possibility of using differences in tax systems of different countries in order to minimize taxes.
Thus, the list of controlled operations was extended by operations between a non-resident and its permanent representative office in Ukraine, the list of countries where the counterparty resides and the list of organizational and legal forms of non-residents.
Law Firm Patriot.Legal specialists on transfer pricing prepared documentation on transfer pricing for operations related to the payment of royalty for a company with foreign investment, which deals with the advertising business in Ukraine.
In 2018, the criteria for recognizing operations as controlled were significantly changed regarding expanding of the list of persons, transactions between whom can be recognised as controlled.
Managing partner, attorney at law