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Ukraine Clarifies that Operational Funding Not Subject to Transfer Pricing Rules

|Approved Changes|Ukraine
Ukraine

Ukraine's State Fiscal Service (SFS) recently published guidance letter No. 15281/6/99-99-15-02-02-15, which clarifies the transfer pricing treatment of operational funding transactions from a non-resident to its permanent establishment in Ukraine. According to the letter, for the 2013 - 2014 tax years, operational funding transactions are not considered controlled transactions as long as the f…

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