13:27 PM Tuesday, January 23, 2018
The First Advance Pricing Agreement Negotiations Process In Ukraine
Advance Pricing Agreement negotiations
image/svg+xml Kyiv Lutsk Rivne Zhytomyr Lviv Ternopil Khmelnytskyi Uzhgorod Chernivtsi Vinnytsia Chernigiv Sumy Kharkiv Poltava Cherkasy Kirovohrad Lugansk Dnipropetrovsk Donetsk Zaporizhzhia Mykolaiv Odesa Kherson Simferopol Sevastopol Ivano- Frankivsk

EY is acting as a taxpayer’s advisor in the first Advance Pricing Agreement negotiations process in Ukraine. Following the results of the given procedure, it is expected for the first APA to be concluded in Ukraine for transfer pricing purposes.

Photo: Igor Chufarov, Partner

One of the leading companies in the Ukrainian agricultural sector is intending to conclude unilateral APA. The taxpayer submitted a formal application with the State Fiscal Service of Ukraine (hereinafter – "SFS") following preliminary discussions with the representatives of the SFS, conducted calculations and feasibility study.

An APA is a contract, concluded for a limited period of time (at the moment – for up to 5 years) between a large taxpayer and the SFS, and allows an interested party to obtain compliance certainty with respect to transfer pricing facts, transfer pricing methodology, and arm’s length range of results.

Entering into an APA is a multiple step process. Once a formal application is received, the SFS conducts preliminary evaluation and discussions between the representatives of the SFS and the taxpayer take place. Consequently, the SFS informs if it is willing to consider the APA proposal further.

Igor Chufarov, Partner, and Oleksandr Fedosieienko, Manager, are providing APA support in EY.

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