Ukraine Clarifies Available Sources of Comparable Information for the Tax Authority

The Ukraine State Fiscal Service recently issued a guidance letter concerning the sources the tax authority may use for obtaining comparable information for transfer pricing purposes. These include:

• Comparable uncontrolled transactions executed by the taxpayer or its counterparty with other unrelated parties;
• Any publicly available information on comparable transactions and the parties involved;
• Other sources that the taxpayer used to legally obtained information if the taxpayer provides tha…