Compliance
How Ukraine’s Updated Transfer Pricing Reporting Rules (Order №312) Affect Foreign & Related-Party Transactions
Ukraine has introduced new identifiers and codes for related-party and economic relatedness in its transfer pricing reports starting September 1, 2026 – here’s what taxpayers need to know to stay compliant.
By NomadicTax Research Team • 5-8 min read • September 11, 2026
## Overview
On **September 1, 2026**, Ukraine officially updated the reporting requirements for **controlled transactions**, meaning transactions between related parties where transfer pricing rules apply. This comes via Order of the Ministry of Finance № 312, registered under № 931/46325. ([tax.gov.ua](https://tax.gov.ua/en/mass-media/news/1047864.html?utm_source=openai))
These changes affect the way businesses classify related parties and submit their annual report, including new identifiers for forms and expanded codes in the annex for “related persons.” ([tax.gov.ua](https://tax.gov.ua/en/mass-media/news/1047864.html?utm_source=openai))
## What’s New
- **New form identifiers:**
- Form J0104708 – Main Report on controlled transactions
- Form J0147108 – Annex to the Report
- Form J0147208 – Related Person Information annex ([tax.gov.ua](https://tax.gov.ua/en/mass-media/news/1047864.html?utm_source=openai))
- **Expanded codes for related‐party relationships:** Codes **525 and 526** added in the “Information on related persons” annex to reflect *economic relatedness* (as per Sub-paragraph 14.1.159 of Article 14 of the Tax Code). ([tax.gov.ua](https://tax.gov.ua/en/mass-media/news/1047864.html?utm_source=openai))
- Reports for 2025 already submitted are still valid and do not need re-submission solely because of the form change. ([tax.gov.ua](https://tax.gov.ua/en/mass-media/news/1047864.html?utm_source=openai))
## Why This Matters: Practical Implications
**For Multinational Enterprises (MNEs) and Large Ukrainian Entities**
- If your business falls under controlled transactions rules, you must ensure new codes 525/526 are applied correctly to reflect economic relatedness.
- Any failure to use updated forms or omission of economic relatedness could trigger risk assessments or audit exposure.
**Example:**
A Ukrainian parent company and its overseas subsidiary enter into loan arrangements. Under the new rules, you must use code 526 (if suitable) in identifying them as economically related, not just legally related. Reporting bond interest payments under the new identifiers ensures compliance.
## Action Steps to Stay Compliant
| Task | Executor | Deadline / Notes |
|---|---|---|
| Review relationships with foreign and domestic entities for legal *and* economic relatedness | Tax / transfer pricing team | Immediate – as new codes must be reflected in upcoming reports |
| Update internal reporting templates to match new identifiers (J0104708 etc.) | Finance / Tax departments | Before filing next controlled transactions report (for FY 2025 unless already submitted) |
| Confirm that reports submitted in older formats aren’t erroneously duplicated | Finance / Compliance team | Ensure no extra submissions if full report already filed under old form for all months |
## Penalties / Upside
- **Risks if non-compliant**: Wrong classification can lead to adjustments, penalties for undervaluation/overvaluation, and audit challenges.
- **Upsides**: Clearer rules aid defensibility; using “economic relatedness” may help taxpayers better structure transactions to reflect substance over form.
## Conclusion
Those engaged in cross-border or intracompany dealings must swiftly update their systems to align with Ukraine’s new reporting standards from September 2026. Identifying economic relatedness, using proper forms, and ensuring accurate reporting will mitigate risk and avoid surprises during audits.