24 August 2021
The Ukraine State Fiscal Service recently issued a guidance letter concerning the sources the tax authority may use for obtaining comparable information for transfer pricing purposes. These include:
The letter also provides that the tax authority is required to use the same sources of information as the taxpayer unless it is proven that other sources provide a higher level of comparability of the commercial and financial transactional conditions. Lastly, the letter clarifies that the tax authority is disallowed from using information sources that are not publicly available or only available to public authorities, unless the information was obtained in the course of an audit of a taxpayer's transfer pricing compliance.
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