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Ukraine Amends Criteria for Determination of Related Parties and Controlled Transactions

10 January 2025

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Approved Changes

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Ukraine

The State Tax Service of Ukraine has issued notice on changes to the transfer pricing rules in regard to the determination of related parties and controlled transactions. In particular, the criteria for recognized parties as related have been expanded to include the following: A resident legal entity is considered related to a non-resident if its revenue from sales of goods, works, or services to that non-resident constitutes 75% or more of the resident legal entity's total revenue from sales to all non-residents and constitutes 50% or more of its total annual income. A resident legal entity is considered related to...