We would like to remind taxpayers that October 1, 2026 is the statutory deadline for filing the Report on Controlled Transactions for the 2025 reporting year.
Failure to meet this deadline or failure to file the Report may result in significant financial penalties. Under paragraph 120.3 of Article 120 of the Tax Code of Ukraine, the penalty for failure to submit the Report or for late submission may amount to UAH 998,400.
However, timely filing of the Report is only one aspect of transfer pricing compliance. Businesses should also ensure that the relevant transfer pricing documentation is prepared in advance and kept up to date. Pursuant to subparagraph 39.4.4 of Article 39 of the Tax Code of Ukraine, the tax authorities may request such documentation in respect of specific controlled transactions.
Failure to provide the requested transfer pricing documentation may result in an additional penalty of up to UAH 665,600 (as of 2026).
ArtesLex team provides comprehensive support on transfer pricing matters, covering the entire compliance process, from transaction analysis and risk assessment to interaction with the tax authorities.
Our services include:
- consulting on transfer pricing rules and tax planning;
- preparation and filing of the Report on Controlled Transactions;
- preparation and ongoing support of transfer pricing documentation;
- legal and tax risk analysis, including assessment of potential tax implications;
- assistance and representation during tax authority audits;
- representation of clients in tax disputes.
We help businesses meet transfer pricing requirements in a timely manner, mitigate tax risks, and effectively address potential issues raised by the tax authorities while ensuring compliance with Ukrainian and international legislation.
We hope that the above information will be useful to you. Please note, however, that this information is of a general nature and does not cover all potential aspects and risks, which may be further analyzed and provided in a separate detailed consultation. Do not hesitate to contact us should you have any questions, or should you require additional information or assistance from our side.
Author: Vasyl Klym, attorney-at-law and partner at ArtesLex
September 3, 2026
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