The EUCON Legal Group in 2019 initiated a series of events dedicated to the application of laws in the field of TP. The lack of practice and experience in the field of transfer pricing in Ukraine, as well as the complexity of laws in the field of TP and its variability, indicate the need for such events.
Throughout the series of seminars on “Transfer Pricing: Practical Aspects”, EUCON experts are sharing practical case studies with participants, helping to deal with problematic issues.
Thus, on March 21, 2019, the second workshop about “Transfer pricing: practical aspects” was held in Kyiv.
The workshop began with the introductory words of the managing partner of the EUCON Legal Group, Yaroslav Romanchuk, who welcomed the participants and introduced them to the concept of the event: “We are glad to announce to our participants that the workshop on “Transfer Pricing: Practical Aspects” continues and will be held monthly during the year”. Larysa Vrublevska, auditor, partner, head of transfer pricing practice of the EUCON Legal Group, added: “The main value of our workshop is that we have summarized our entire practice for accountants. We will show examples of justifying the price level for different types of transactions, using financial data segmentation procedures.”
Larysa Vrublevska also discussed the inventory of controlled transactions for 2018, paying attention to the details of calculating the cost criterion, and focused on the issue of business transactions between a non-resident and his permanent representative office in Ukraine, told about the features of the List of CMU No. 480 and No. 1045.
Victor Biloblovsky, tax consultant of the EUCON Legal Group, talked about the application of the method of comparative uncontrolled prices (CUP). Thus, the expert noted that the CUP method seems to be one of the simplest methods, but it is not easy to apply. The being confident for 100 % is essential in order to use such method in the comparability of the peculiarities (commercial and financial) of goods or services and the terms and conditions of transactions.
The next presentation of Zhanna Biloblovska, the auditor, tax consultant of the EUCON Legal Group, on “Economic Analysis. Application of methods based on the calculation of profitability. Segmentation of financial statements. Accounting aspects. Practical examples” was very relevant and useful. The speaker pointed out the need for segmentation of financial statements, economic justification of the algorithm for the distribution of income and costs.
Yuriy Chebotar, Deputy Head of Transfer Pricing Practice, Tax Advisor of the EUCON Legal Group, spoke about comparable transactions and comparable legal entities. The speaker drew attention to the fact that the resale price method and the “cost plus” method can be used with greater confidence when comparing with own transactions.
After a detailed analysis of the pricing method selection procedures, participants were introduced to a practical step-by-step case of justifying the price level in controlled import transactions. Economic and comparative analysis was presented in detail using a practical example. The last court practice was also reviewed.
In continuation of a series of thematic events, the EUCON Legal Group organizes on May 31 the annual International Forum “Transfer Pricing and Tax Planning – 2019”.