Tax authorities’ requests in reference to para. 140.5 of the TCU | Transfer Pricing


Tax authorities’ requests in reference to para. 140.5 of the TCU

The tax authorities monitor taxpayers’ transactions with both the counterparties registered in low-tax jurisdictions and those whose legal form is included in the CMU’s list.

According to para. 140.5 of the TCU, taxpayers are required to make a 30% tax base adjustment of the amount of such transactions.

If such 30% adjustment is not made in the CIT Return in accordance with para. 140.5 of the TCU, the tax authorities may request an explanation of why it has not been made.

  • Have you received a request from the tax authorities for additional information in reference to para. 140.5 of the TCU?
    According to current legislation, a taxpayer must provide an official response to the tax authorities’ inquiry. We can help prepare such a response.
  • Do you want to avoid a 30% tax base adjustment? To avoid making a 30% adjustment, a taxpayer may prepare transfer pricing documentation in accordance with Article 39 of the TCU to confirm that the terms of transactions are consistent with the arm’s length principle. We will be happy to assist you in preparing your TP documentation. We provide our services to more than several hundred leading Ukrainian and international companies.


Oleksandr Yampolskyi

Oleksandr Yampolskyi

Director, Tax & Legal

Career. Oleksandr has 12 years of experience in tax consulting. At the start of his career, Oleksandr advised on corporate taxation, VAT, business structuring, and tax support of audits. He was at the... More

Maksym Zaichenko

Maksym Zaichenko

Senior Manager, Tax & Legal

Maksym joined Deloitte Ukraine in 2017 and has five years of experience in consulting on Ukrainian and international taxation. He participated in transfer pricing engagements on tax compliance, planni... More