We would like to remind that October 1, 2025 is the deadline for submission of the Report on the Controlled Transactions for the year 2024.
Failure to comply with this obligation can lead to significant financial consequences: pursuant to paragraph 120.3 of Article 120 of the Tax Code of Ukraine, the penalty for non-submission, or for late submission of the Report can reach up to UAH 908,400 (as of 2025).
It is also important not only to ensure the timely submission of the Report but to prepare the transfer pricing documentation in advance as well. According to subparagraph 39.4.4 of Article 39 of the Tax Code of Ukraine, the tax authorities are entitled to request such documentation concerning specific controlled transactions.
Failure to provide transfer pricing documentation may result in a fine of up to UAH 605,600 (as of 2025).
Should you require our assistance, please be reminded that ArtesLex team offers a comprehensive range of services in the field of transfer pricing, including:
– advisory services regarding the application of transfer pricing rules and tax planning;
– preparation and submission of the Report on the Controlled Transactions;
– drafting and maintenance of the transfer pricing documentation;
– legal analysis of risks and assessment of potential tax implications;
– support during audits conducted by the tax authorities;
– representation of clients’ interests within the tax disputes.
We assist our clients in minimizing tax risks, avoiding penalties, and ensuring full compliance with both 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 2, 2025
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