The problems of transfer pricing in Ukraine
Journal Title: Формування ринкових відносин в Україні. Збірник наукових праць - Year 2018, Vol 4, Issue 4
Abstract
Transfer pricing was first legislated by the US Tax Code. An unbiased assessment of the terms of the transaction of the interrelated participants was embodied in the concept of "extended hand". Different mechanisms of transfer pricing control operate in developed countries. Transfer pricing became relevant in Ukraine with the development of financial and industrial groups. The difference in the tax burden of different countries and the redirection of the total income for taxation to countries with lower taxes or tax avoidance altogether allows international companies to significantly reduce their tax burden. Such a simple and widespread scheme for reducing tax burden requires special attention from any state. Control over transfer pricing in Ukraine was launched in 2013. The principle of "extended hand", the criteria for mutual "connection of persons", the content of controlled operations were reflected in the Tax Code of Ukraine in 2015. The systematization of the regulatory framework for transfer pricing in Ukraine has been carried out in accordance with international standards and Recommendations of the Organization for Economic Cooperation and Development (OECD) for multinational corporations and tax services. The controlled volume of business operations now exceeds UAH 10 million. Evading large taxpayers of income tax from paying in preferential tax regimes or reducing its rates by five percent and more than in Ukraine is now controlled by the fiscal service. Large taxpayers can enter into an agreement with the fiscal service of Ukraine for the transparent formation of transfer prices and the conduct of tax operations in the territories of preferential tax regimes.
Authors and Affiliations
O. ANDRUS
Keywords
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- DOI 10.5281/zenodo.1252290
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