Ukraine Clarifies Treatment of Transactions with German Company as Controlled for Transfer Pricing Purposes
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 guidan…
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