The Ukraine State Fiscal Service recently issued a guidance letter concerning the treatment of transactions between a resident enterprise and a non-resident that gained and lost its status as a related enterprise of the resident enterprise during the course of a tax year. The letter clarifies that in determining whether the transactions with the non-resident are controlled transactions for transfer pricing purposes, only the period during which the non-resident has related status will be considered in determining if the relevant thresholds are met. This includes the annual income of the resident from any activity exceeds UAH 150 million (net of...