The workshop season of the Association of Taxpayers of Ukraine (APPU) is over! On December 11, 2020 Larysa Vrublevska, Auditor, Partner and Head of Transfer Pricing Practice gave the final for this year lecture “Transfer pricing in 2020. New rules, new reporting. Algorithm of actions after the end of the reporting period. Control and inspections in quarantine”.
During her speech the lecturer focused on amendments to the Law 466-IX and 14.1.113-3. of the Tax Code of Ukraine on the international group of companies, issues of documentation and features of reporting on Transfer Pricing for 2020, features and procedures of inspections and monitoring and general information about the Contract.
Besides, the expert listed all changes in the Transfer Pricing for the year 2020, in particular: Larysa Vrublevska reviewed the new organizational legal forms added to the List No. 480, the new criteria for the entities to be recognized as associated (the entities shall be deemed as the associated ones with the threshold 25%, organizations without the status of legal entity), the new types of controlled transactions, additional methodology for intangible asset transactions and restructuring transactions (according to National or International Valuation Standards), changes in the reasonable economic cause (business purpose) (paragraph 140.5.15 of the Tax Code of Ukraine), taxation (15%) of constructive dividends since 2021 (paragraph 14.1.49 of the Tax Code of Ukraine) and expansion of the list of transactions for 30% adjustment (paragraph 140.5.5-1 of the Tax Code of Ukraine).
At the end Ms. Larysa Vrublevska described internal comparable uncontrolled transactions and the resale price method.
So, the regular season of APPU workshops is coming to its end, however, the new one is coming soon!