Controlled transactions: growth in reporting and amounts in Ukraine as of early October

As of early October 2023, taxpayers had submitted 2,797 reports on controlled transactions for 2024 to the State Tax Service of Ukraine. This figure is 11% higher than last year's statistics, and the total declared amount was UAH 3.3 trillion, which is 32% more than in 2023. This indicates an increase in the volume of controlled transactions in Ukraine.

Source — Minfin

The majority of controlled transactions are carried out with non-residents. Many companies use the comparative uncontrolled price method, which accounts for 62% of reports. In addition, 1,754 taxpayers also reported their participation in international agreements, mainly with parent companies registered in Cyprus and the United States.

Companies also took advantage of the opportunity to independently adjust the prices of controlled transactions and tax amounts by submitting income tax returns totaling UAH 2.7 billion. This represents 60% of the total volume of tax adjustments. The data submitted highlights the activity of businesses in the area of transfer pricing control.