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TP Complience Issues Discussed at IFA Ukraine

04 march, 2016, Kyiv, Ukraine

March 3rd, 2016, IFA Ukraine conducted its first in 2016 educating seminar, dedicated to practical aspects of complying with TP regulations.

Senior-level TP specialists covered latest developments in local and international practice with regard to Transfer Pricing. In particular, Seminar agenda was focused on local specifics of TP methods application, recent court practice on TP issues, availability of information sources and their advantages, as well as on substantiation of transfer prices in intragroup transactions.

The Seminar panel was joined by IFA Ukraine Members - Alina Bakulina, EBS, Roman Blazhko, Lavrynovych & Partners, Anna Nikolayko, PwC Ukraine, Oleg Tupchii, KPMG, and Larysa Vrublevska, EUCON.

Oleg Tupchii's presentation was focused on three key elements: analyse of Transfer Pricing methods, specifics of report on controlled transactions for 2015, and latest developments on BEPS Action 13 (Country-by-Country Reporting). With respect to TP methods, Oleg, in particular, outlined top-7 mistakes in application of such TP methods, as C.U.P. method, Resale Price/ Cost + method and TNM method. As for report on controlled transactions, Oled denoted that grouping of similar transactions is now allowed, and there is no obligation to indicate arm's length price per unit and source of information on market prices. Additionally, if taxpayer chose any method except C.U.P., he is allowed to provide aggregated information on the group of such controlled transactions.

Alina Bakulina delivered a detailed presentation on major information sources that could be used to justify prices in controlled transactions, such as stock exchange prices, commercial databases, information on company's own comparable operations etc. Alina also covered deductive and additive approaches in selection of comparable companies.

Larysa Vrublevska conversed on TP documentation with a focus on its preparation and some important points to keep in mind.

Roman Blazhko provided a brief overview of key changes in Ukrainian TP legislation in 2015.

Anna Nikolayko spoke on functional analysis as a basis for selection of Transfer Pricing method. In partcular, Anna explained what is actually a functional analysis, putting emphasis on on its stages, fact finding process, assets and risks studies, as well as on documentation of results.

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