The Ukraine State Fiscal Service recently published a guidance letter concerning the application of the amended transfer pricing rules that entered into force on 1 January 2018 ({News-2018-02-01/A/3-previous coverage}). One of the main changes is that transactions between a permanent establishment (PE) in Ukraine and its non-resident parent are deemed controlled and subject to transfer pricing rules if exceeding UAH 10 million per year. The guidance clarifies that, unlike other taxpayers car…