On 29 October 2026, the State Tax Service published a detailed overview of the Advance Pricing Agreement (APA) mechanism available to large taxpayers in Ukraine. An APA allows a taxpayer to agree in advance with the STS on the transfer pricing methodology for controlled transactions over a fixed period (typically 3–5 years). The article outlines the eligibility criteria, application procedure, required documentation, and the binding nature of the agreement for both parties. This mechanism is designed to provide certainty and reduce transfer pricing audit risks for multinational enterprises operating in Ukraine.
Key Takeaways
- Eligibility: APAs are available to taxpayers with annual controlled transaction volumes exceeding UAH 50 million or those part of a multinational group with consolidated revenue above EUR 750 million.
- Process Timeline: The STS commits to reviewing a complete APA application within 12 months, with a possible 6-month extension for complex cases involving bilateral/multilateral agreements.
- Annual Reporting: Taxpayers with an active APA must submit an annual compliance report confirming that actual transactions adhere to the agreed methodology, due within 30 days of the fiscal year-end.
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.
Source: Read Official Announcement