On December 9, 2016, Larysa Vrublevska, partner, Head of Transfer Pricing at EUCON International Legal Center took part in the II Agrarian Tax Conference. The event was organized by ProAgro information company.
Larysa spoke in the first block with the report on “Transfer pricing: preparation of reports and control of tax risks”. During her speech, she focused on changes in the sphere of transfer pricing and analyzed the bill №5368. This bill makes significant changes to the Tax Code, including to Article 39, which regulates transfer pricing.
One of the most important innovations envisaged by the bill №5368 is an increase in the cost criterion when determining the transaction as controlled, increase of the annual income amount from UAH 50 million to UAH 150 million, as well as the fact that operations with one counterparty will amount to UAH 10 million per annum instead of UAH 5 million. Also, it should be noted that the return of the regulation relating to forward contracts will require a price determination in accordance with the date of the contract. It is also expected that taxpayers must notify the State Fiscal Service authorities of the concluding a forward contract.
In addition, the speaker recalled the responsibility when detecting offenses, and told about the proposal to differentiate the amounts of fines in case of late submission of the report on controlled transactions.
“It is necessary to differentiate the audits relating to non-submission of a report or documentation and audits relating to not inclusion in the report of all controlled transactions, as well as audits on the issues of completeness of accrual and payment of taxes,” said Larysa Vrublevska, concluding her speech.
Video of Larysa Vrublevska’s report:
https://www.youtube.com/watch?v=eL86WYgb5Gg