Ukraine's State Fiscal Service (SFS) has issued guidance letter 513/6/99-99-15-02-02-15/IPK, which explains new rules effective 1 January 2019 for the recognition of transactions performed through intermediaries as controlled for transfer pricing purposes. This includes that where an import or export transaction between a resident and a non-resident is performed through one or more persons (intermediaries) and a transaction by a resident with any such person would not otherwise be recognized…