Ukraine's State Fiscal Service (SFS) has issued guidance letter 423/6/99-99-15-02-02-15/IPK, which clarifies the treatment of transactions with certain U.S. States as controlled for transfer pricing purposes. The letter includes that under the transfer pricing rules, transactions are deemed controlled when conducted with non-residents covered by the Ukraine Cabinet list of tax havens, which includes jurisdictions with low or no taxation or inadequate information exchange with Ukraine, and sp…