Future challenges in Ukrainian transfer pricing disputes
By Svitlana Musienko and Dmytro Donets
Ukraine’s major transfer pricing reforms took effect on 1 September 2013. Generally, the new rules are OECD based, although some exceptions exist.
While these new and technically complicated rules represent untested waters for all stakeholders, it is uncertain whether Ukrainian tax payers may rely on the local judiciary system to protect themselves against the excessive pressure that is likely to be applied by the tax authorities.
With that in mind, it is useful to have a look at the court practice existing to date…
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