On June 15, auditor and partner of the EUCON Larysa Vrublevska spoke at a webinar from the Association of Taxpayers of Ukraine on the topic “Actual issues of transfer pricing and CIC taxation”.
The speaker began the lecture with how to prepare for reporting on controlled transactions, analyzed reporting in the field of transfer pricing for 2022, the issue of the obligation to report and independent adjustments during martial law, the issue of liability provided by legislation for non-submission and late submission of various types of reporting, notification of participation in the MGC, documentation and for providing inaccurate information.
Ms. Larysa also reviewed control in the field of transfer pricing, factors that are taken into account during monitoring, written requests for information on KO, inspections and liability during martial law. The results of the DPS in the successful implementation of the BEPS and GAAR steps, as well as the most widespread shortcomings of the TCU documentation, were not overlooked.
Particular attention was paid to practical aspects: segmentation of accounting data, the criterion of the amount of revenue for the formation of the primary sample, the quality of the final sample, the choice of a period for the analysis and the use of historical data.
The problems of transfer pricing are also an important issue, in particular through the prism of the impact of the covid-19 pandemic, so Larysa Vrublevska voiced the recommended solutions for solving these problems.
The expert analyzed in detail the issues of business purpose, constructive (hidden) dividends, 30% adjustment, controlled foreign companies, CIC reporting, submission of notices, transitional provisions, dismissal and Supreme Court rulings. The speech ended with an overview of the changes proposed by Bill No. 8137 of 10/19/2022.
Larysa Vrublevska received thanks from the webinar organizers, who noted the fruitfulness of the long-term partnership, high professionalism, informativeness, accessibility and depth of the expert’s presentation!