Ukraine Clarifies that Operational Funding Not Subject to Transfer Pricing Rules

Ukraine's State Fiscal Service (SFS) recently published guidance letter No. 15281/6/99-99-15-02-02-15, which clarifies the transfer pricing treatment of operational funding transactions from a non-resident to its permanent establishment in Ukraine. According to the letter, for the 2013 - 2014 tax years, operational funding transactions are not considered controlled transactions as long as the funds were used exclusively to support the activities of the PE. However, the transactions are still …