Transfer pricing

Organizations that span international borders are increasingly facing complex regulatory and tax issues in the different jurisdictions where they operate. Transfer pricing is one of the most complex and important components of tax legislation and is one of the priority areas of tax audits in Ukraine. The significant size of potential tax penalties and the renewal of tax audits related to transfer pricing during the state of war confirm its growing importance. We offer a range of solutions for transfer pricing management so you can ensure compliance with local regulations. 

Read the brochure describing our services

Our approach 

There is greater scrutiny of transfer pricing the world over. Only a global, multi-layer approach can bring simplicity to this fast-evolving issue. Our global partnership in more than 100 countries provides the vital expertise in tracking developments such as new legislation and court/tribunal rulings in each jurisdiction, through direct contact with our transfer pricing experts who have deep industry know-how and the local and international expertise necessary.  

Our International Transfer Pricing Community brings together specialists from across disciplines, including economists to help with value chain analysis: a vital tool to align transfer pricing with economic value creation and establish transfer prices for intangibles. 

In Ukraine, as in many other countries, transfer pricing rules are constantly changing, which can lead to tax risks for taxpayers. Experts of Forvis Mazars Ukraine have many years of experience in transfer pricing, constantly monitor changes in legislation, and are always ready to help you with all questions regarding this complex tax regime. 

Our service begins with a diagnostic risk assessment that seeks to highlight areas for savings, as well as exposure. We then work closely with you to make sure you can meet your documentation obligations and optimize your tax positions. 

Our services: 

• Identification of controlled transactions 
• Consultation on the application of transfer pricing rules 
• Development of intra-group Transfer Pricing Policies 
• Audit of Transfer Pricing Documentation (Local Files) 
• Transfer pricing compliance audit 
• Preparation of Reports on Controlled Transactions 
• Preparation of Notifications on Participation in a Multinational Entities Group 
• Preparation of Transfer Pricing Documentation 
• Preparation of Country-by-Country reports (CbC Reporting) 
• Preparation of Master Files 
• Analysis and justification of the business purpose of the controlled transactions 
• Support of tax disputes related to the application of transfer pricing rules 
• Preparation of documentation to justify prices or profitability to avoid tax adjustments under paragraphs 140.5 of Article 140 of the Tax Code of Ukraine 
• International business restructuring considering transfer pricing requirements

Our people  

Our team consists of experienced tax specialists and transfer pricing experts with country and sector specific tax and industry knowhow, accountants and economists, which ensures that we can provide, develop and implement customized transfer pricing solutions that fit with our clients’ commercial and tax strategies. 

In 2023 and 2024, Forvis Mazars in Ukraine was ranked amongst the top performing tax firms in Ukraine according to ITR World Tax firm ranking (category: Transfer pricing).