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

|Approved Changes|Ukraine
Ukraine

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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