Ukrainian Parliament Considering Draft Law to Align Transfer Pricing Regime with Latest OECD Guidelines and BEPS Actions

The Ukrainian Parliament is considering the Draft Law on Amendments to the Tax Code of Ukraine Regarding Further Improvement of Transfer Pricing Rules, which was submitted on 4 September 2026. The law is primarily meant to fully align Ukraine's transfer pricing rules with the 2022 OECD Transfer Pricing Guidelines and Actions 8–10 of the BEPS Action Plan to facilitate Ukraine's accession process to the OECD. The amendments:

• Extend the arm's length principle to domestic transactions between r…