Compliance
How Ukraine’s New Controlled Transaction Reporting Rules Affect Cross-Border Businesses
Ukraine updated its reporting form for related-party transactions, introducing economic relatedness codes that could impact transfer pricing and compliance across borders.
By NomadicTax Research Team • 5-8 min read • September 14, 2026
## What’s changed?
From **September 1, 2026**, Ukraine requires all **controlled transactions reports** to use an updated form. Two new related-party codes — **525** and **526** — have been added to the annex “Information on related persons,” to reflect *economic relatedness* as defined in Sub-paragraph 14.1.159, Article 14 of the Tax Code. ([tax.gov.ua](https://tax.gov.ua/en/mass-media/news/1047864.html?utm_source=openai))
Previously submitted reports for FY 2025 do **not** need re-submission solely for the form change. The transition applies only going forward. ([tax.gov.ua](https://tax.gov.ua/en/mass-media/news/1047864.html?utm_source=openai))
## Why this matters for businesses abroad and multinational groups
- These codes **alter how related parties are identified** in controlled transactions, which could affect how transactions are benchmarked and whether tax authorities view transactions as comparable to independent-party ones.
- Non-compliance may lead to **adjustments, penalties**, or risk of double taxation if documentation isn’t aligned.
- Businesses that operate in multiple countries should review their current structure to understand whether **economic relatedness** under Ukraine’s definition applies.
## Actionable steps
1. **Review structure of relationships**: Entities must examine whether existing related-party relationships fit the new criteria for economic relatedness. If yes, ensure they are covered in reporting with correct codes.
2. **Update internal documentation**: Transfer-pricing documentation should be expanded to demonstrate economic substance and support any grouping under these new codes.
3. **Train compliance staff or advisors**: Accounting and tax teams should be familiar with the changes to avoid misreporting.
4. **Coordinate across jurisdictions**: This change could interact with OECD BEPS and local transfer pricing laws elsewhere — coordinated compliance can reduce risks.
## Example
A multinational group with subsidiaries in Ukraine and elsewhere had been reporting group-owned finance company loans but did not consider the borrower as “economically related” under Ukrainian law. With the new codes, they must assess whether the entities are considered economically related and, if yes, provide the extra disclosure. If they fail to do so, authorities could adjust the pricing of those loans or treat the transactions differently.
## Key takeaways
- The updated form applies *only for reports submitted after September 1, 2026*.
- Past reports (for FY 2025) are valid without resubmission just due to form change.
- Proper entity assessments and documentation are essential to avoid compliance risk.
- This is part of Ukraine’s move toward more rigorous transfer pricing aligned with global standards.