The State Tax Service of Ukraine issued has guidance regarding the application of Article 39.2.1.1 of the Tax Code and the 1995 Germany-Ukraine tax treaty in relation to potential controlled transactions with certain German organizational and legal forms. Article 39.2.1.1 includes conditions for a transaction to be considered controlled for transfer pricing purposes. In particular, the guidance concerns subparagraph "d" of Article 39.2.1.1, which provides that controlled transactions include transactions with non-residents that do not pay income tax (corporate tax), including on income from outside the jurisdiction in which they are based, and/or are not resident for tax purposes in...