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VI Annual Conference - Transfer Pricing: Risk Mitigation

  • IQ BUSINESS CENTER Bolsunovska St, 13-15, Kyiv, 01014 Ucraina (map)

Program draft

9:00 – 9:30

Registration. Welcoming coffee

9:30 – 10:00

Welcoming address to the participants

  • Nina Yuzhanina, Chairman of the Committee on Taxes and Customs Policy of Ukrainian Parliament, Verhovna Rada (invitation extended)

  • Deputy Minister of Economic Development and Trade of Ukraine (to be confirmed)

  • Bogdan Dubas, Director, Derzhzovnishinform (DZI)

10:00 – 11:45

Session 1. The latest interpretation of the changes straight from the sources.

Moderated by Dmitry Mikhailenko.

10:00 – 10:20

Recent amendments to the Tax Code of Ukraine regarding Transfer pricing. Impact of the type of assets and their usage on the Transfer pricing justification

  • Viacheslav Krugliyak, Head of the Transfer Pricing Inspection Department, Audit division of the State Fiscal Service of Ukraine (SFSU)

10:20 – 10:40

Annual financial reporting and tax gains (losses) from transactions with low tax territories or legal form of the entity. Transfer pricing justification procedure; profit or loss adjustments.

  • Olexsiy Zadorozhniy, Acting Department Director of Methodology and Regulatory Development of the State Fiscal Service of Ukraine (SFSU)

10:40 – 11:05

Interpretation arguments of the Ministry of Finance and SFSU as to Transfer pricing application. Bonuses, writing off debts, distribution of dividends, third-party payments etc.

  • Vitaliy Smerdov, Partner, Crowe LF Ukraine

11:05 – 11:30

Questions & Answers

11:30 – 11:55

Coffee Break

11:55 – 13:50

Session 2. International Angle. Transfer pricing and BEPS plan – overlap points.

Moderated by Roustam Vakhitov

11:55 – 12:15

Anti-offshore draft law (BEPS). Workbook and country-by-country reports: who is to submit, requirements and extent of the report. Related party’s identification: threshold rise (25%) and the inclusion of the related party’s criteria with indebtedness and expense allocations for a single counterparty. Extension of Transfer pricing rules applicable to “meaningful dividends”. Additions to the list of Permanent Establishments. 

  • Eugene Kozlov, Counselor to the Minister of Finance of Ukraine, Reform facilitation office of the Ministry of Finance.

12:15 – 12:35

Transfer pricing in terms of BEPS: what taxpayers should expect.

  • Olena Zhukova, Director, Audit firm “Saivena-Audit”, Head of the Workgroup on Transfer pricing in the Public Council under the SFSU.

12:35 – 12:55

Implementation of Country-by-Country Reporting (European countries record). Useful consequences for Ukrainian companies.

  • Roustam Vakhitov, Partner,  Crowe LF Ukraine

12:55 – 13:20

Preventing & resolving Double Taxation: Advanced Pricing Agreement (APA) and Mutual Agreement Procedures (MAP) within the EU. Lessons to be learned for Ukrainian companies. OECD guidance on Transfer pricing: examples of methods used.

  • Federico Vincenti, ILM Tax & Transfer Pricing, Crowe Valente, Italy

13:20 – 13:35

Questions & Answers

13:35 – 14:20


14:20 – 16:10

Session 3. Transfer pricing Report and Documentation. Examples and Recommendations.

Moderator to be confirmed

14:20 – 14:40

Hands-on recommendations for Transfer pricing justification for specific transactions: Imports, Exports (carry-over stock), Corporate rights sales, Logistics, IT-services.

  • Olga Bogdanova, Partner, Crowe Audit and Accounting Ukraine LLC

14:40 – 15:00

Price Agency “Argus” activities regarding Transfer pricing

  • Kirylo Portnov, Research Director on Pricing and Logistics, International Price Agency “Argus” (to be confirmed)

15:00 – 15:20

Transfer pricing in financial transactions – interest rates, royalty, etc. (to be confirmed)

15:20 – 15:40

Tax authority is requesting information as to controlled transactions – how to win.

  • Mykola Mishin, Transfer pricing Group Leader, KPMG Ukraine

15:40 – 16:00

First report submission for Permanent Establishments and documentation preparation. What to pay attention to. What activities to choose to compare with. Who is obliged to report? Non-for-profit organization representative offices.

  • Dmitry Mikhailenko, Partner, Crowe LF Ukraine  

16:00 – 16:10

Questions & Answers

16:10 – 16:30

Coffee Break

16:30 – 18:00

Сесія  4. Court cases on Transfer Pricing.

Moderated by Olena Zhukova

16:30 – 16:55

The current attitude of the SFSU in disputes with the Taxpayers. The latest cases.

  • Dmitro Pavlovich, Head of Department, Administrative Appeals and Legal Support Division, State Fiscal Service of Ukraine

16:55 – 17:15

Digest of case law.

  • Nataliy Blazhivska, President, International Fiscal Association Ukraine (IFA Ukraine), Judge

17:15 – 17:40

Legal support of inspections and disputes on Transfer pricing. Facts used for the defense of the taxpayer in disputes and inspections concerning Transfer pricing. (to be confirmed)

  • Ivan Shinkoremko, PhD, Partner, Leader of Customs law and Transfer pricing Practice, KM Partners

17:40 – 18:00

Questions & Answers. Closing remark.

Download the Agenda draft