Ukraine Transfer Pricing Documentation Requirements
Ukraine requires transfer pricing documentation where a taxpayer's turnover exceeds UAH 150 million and a controlled transaction exceeds UAH 10 million, with a Master File for groups above EUR 50 million in revenue. A report on controlled transactions is filed by 1 October, and a fresh benchmarking search is required every year.
Requirements at a glance
| Requirement | Threshold | Deadline | Deadline type | Language | Penalty |
|---|---|---|---|---|---|
Master File Required | Group consolidated revenue > EUR 50m in the preceding year | On request | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. Once requested, it must be provided within 60 days. | UK | Yes (UAH 528,600 for non-submission) |
TP documentation Local documentation
Required | Annual turnover > UAH 150m and a controlled transaction > UAH 10m | On request | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. Once requested, it must be provided within 30 days. | UK | Yes (UAH 352,400 for non-submission) |
Controlled transactions report Annual filing | Taxpayers with controlled transactions | By 1 October of the following year | Submission deadline The documentation must be filed with the tax authority by the date shown. | UK | Yes |
CbC report Required | Group revenue ≥ EUR 750m | 12 months after fiscal year-end | Submission deadline The Country-by-Country report is filed by the group's ultimate parent entity; a local notification identifying the reporting entity is filed separately. | — | Yes |
Calculate your exact Ukraine deadline
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Scope of the documentation obligation
Transfer pricing documentation must be prepared where a Ukrainian taxpayer’s annual turnover exceeds UAH 150 million and the amount of a controlled transaction with a related counterparty exceeds UAH 10 million as of the end of the year; where the transaction is between an ultimate parent and its permanent establishment in Ukraine, only the UAH 10 million transaction threshold applies. The Master File applies to entities in groups with consolidated revenue above EUR 50 million in the preceding year. The local documentation is produced within 30 days of a request and the Master File within 60 days.
Distinctive features of the Ukrainian regime
The defining feature of the Ukrainian regime is the report on controlled transactions, a detailed annual filing due by 1 October of the following year that discloses every controlled transaction together with the testing parameters: the tested party, the method, the profit level indicator and its numeric value, and the database used. This gives the tax authority a structured, transaction-level view in advance of any documentation request. Penalties for non-submission are fixed and substantial, set at UAH 528,600 for the Master File and UAH 352,400 for the local documentation. Aggregation is permitted where transactions are closely related, continuous, or regular. The limitation period for transfer pricing assessments is seven years, with the running of time suspended for a defined period covering the pandemic and martial law.
Benchmarking and comparables
A local benchmarking study using Ukrainian comparables must be used where the tested party is a Ukrainian entity. Both single-year and multi-year analysis are possible, but the best practice is to use a single year similar to the year of the controlled transaction, with any multi-year analysis substantiated in the documentation. A fresh benchmarking search is required every year under the Tax Code, a position the tax authorities support. The limitation period for transfer pricing assessments is seven years from the deadline for filing the corporate profit tax return.
Frequently asked questions
What does the Ukrainian report on controlled transactions disclose?
It discloses every controlled transaction for the period together with the testing parameters: the tested party, the method, the profit level indicator and its numeric value, and the database used. It is filed by 1 October of the following year.
This guide is an informational research aid prepared by Comp-Press and is not tax or legal advice. Transfer pricing rules change; verify current requirements before relying on them for filing.