The State Fiscal Service of Ukraine (SFS) has published a letter outlining certain transfer pricing changes with effect from 1 January 2019. This includes:
- New criteria for determining controlled transactions, which include internal settlement transactions between a non-resident and its permanent establishment in Ukraine and certain transactions involving unrelated intermediaries ({News-2019-02-25/A/2-previous coverage});
- The application of the substance of form principle based on the actual…