The Ukraine State Fiscal Service recently published guidance letter 1358/6/99-99-15-02-02-15/ІPK on the treatment of the salary payments to non-resident individuals as controlled for transfer pricing purposes. The letter provides that such payments will be deemed controlled if the standard thresholds for the year are met, which include that the Ukrainian taxpayer's annual income exceeds UAH 150 million and the annual transactions (salary payments) with the non-resident exceed UAH …