On 2 July 2025, Larysa Vrublevska, Partner and Head of the Transfer Pricing Practice at EUCONLAW Group, gave a presentation during a webinar hosted by the Association of Taxpayers of Ukraine. Her presentation was entitled “Current Issues in Transfer Pricing 2025.”
Ms Vrublevska discussed the legislative changes in the field of transfer pricing (TP) that came into effect on 1 January 2025 and thereafter. She highlighted not only the legal updates but also practical issues related to reporting for 2024 amid strengthened TP oversight. She offered recommendations on enhancing the quality of taxpayer documentation procedures, including the preparation of economic and comparability analyses for controlled transactions.
Among the key changes introduced from 1 January 2025, she outlined:
- the introduction of a new criterion for determining related-party relationships among legal entities;
- a comprehensive revision of the list of jurisdictions;
- new aspects of monitoring transactions with non-residents that have specific organisational and legal forms;
- updated penalty thresholds.
Ms Vrublevska gave particular attention to the preparation of transfer pricing documentation. She stressed the importance of the information required, principles of documentation, approaches to selecting pricing methods, conducting functional analysis, and segmenting financial reporting indicators. She also explored strategies for grouping controlled transactions and documenting the search for comparable entities.
The presentation also addressed a number of important issues, including audits, monitoring of controlled transactions, the automatic exchange of tax information, liability during martial law, procedures for self-adjustments, taxation of constructive (hidden) dividends, and other current regulatory matters in the field of TP.
Ms Vrublevska not only clarified current requirements in transfer pricing but also provided practical guidance on preparing for audits. Her presentation served as a valuable source of insight for professionals working in tax planning and compliance.