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
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
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