2017 started with amendments to the Ukrainian customs legislation. Following a recent Cabinet of Ministers’s meeting, Ukrainian exporters obtained a right to change tax declarations in case of price correction of goods for transfer pricing. This allowed for legitimizing year-end adjustment which is widespread in developed countries.
This is about selling goods during the year for a planned, often a permanent price with possible price correction based on the financial year-end results to match transfer pricing rules. Moreover, this change is one of the steps taken by the Government toward practical realization of signing agreements on prior approval of prices in controlled operations (APA) for transfer pricing purposes.
Initiative of implementing this changes belong to transfer pricing group at KPMG in Ukraine, specifically to Maksym Voytsehovsky, Nazar Galko and Roman Koren, as a result of clients’ case, and was implemented with the help of Business Ombudsman Council. KPMG in Ukraine will continue working on improvement of Ukrainian legislation and will try to initiate widening correction prices scheme on importers as well.