Compliance
Navigating Ukraine’s 2026 Transfer Pricing Reporting Update
Starting September 1, 2026, Ukraine has revamped its reporting for controlled transactions—here’s what businesses must know about the updated form, new codes, and how to stay compliant under the Tax Code.
By NomadicTax Research Team • 5-8 min read • September 13, 2026
## What changed?
On **September 1, 2026**, the State Tax Service of Ukraine introduced an **updated form** for the Report on Controlled Transactions. Two new codes—**525 and 526**—were added to the Annex “Information on Related Persons”, reflecting “economic relatedness” under Sub-paragraph 14.1.159, Paragraph 14.1, Article 14 of the Tax Code of Ukraine. ([tax.gov.ua](https://tax.gov.ua/en/mass-media/news/1047864.html?utm_source=openai))
Previously submitted reports for the year 2025 remain valid and **do not require resubmission** solely due to the form update. ([tax.gov.ua](https://tax.gov.ua/en/mass-media/news/1047864.html?utm_source=openai))
## Who this affects
- **Multinationals and groups** with cross-border related-party transactions.
- **Domestic entities** involved in significant internal transactions, even without cross-border elements if economic relatedness applies.
- Entities preparing their 2025 year-end or quarterly filings where these new codes apply.
## How to comply
1. **Update reporting procedures** to include codes 525 and 526 wherever applicable in Annex “Information on Related Persons”.
2. **Train your tax and finance staff** on what constitutes “economic relatedness” under the new provision.
3. **Review your list of related parties**—ensure it aligns with the definitions and examples in Sub-paragraph 14.1.159.
4. **e-portal readiness**—the electronic form is already available on the State Tax Service portal; test internally to confirm proper data capture. ([tax.gov.ua](https://tax.gov.ua/en/mass-media/news/1047864.html?utm_source=openai))
## Practical examples
| Scenario | Action Needed |
|---|---|
| A multinational group sharing management services within group | Identify if recipient entities are related parties and report using new codes when these influence economic terms. |
| A company leasing premises to a related party at below-market rent | Consider economic relatedness and reflect in reporting with proper code. |
| A business with no changes under old codes | Still update for future filings; past filings remain valid. |
## Consequences of non-compliance
- Missing or mis-applying the new codes may lead to **audit risk**.
- Underreporting relationships might trigger reassessments or penalties.
- Transparency issues could affect eligibility for certain reliefs or cooperative compliance status.
## Takeaways
- The update signals Ukraine’s intention to strengthen transfer pricing rules and better align with OECD/BEPS standards.
- Act before your next reporting deadline.
- Seek assistance from transfer pricing experts if unsure whether economic relatedness applies.
If you'd like, I can also provide comparisons with policies in neighboring jurisdictions—helping you plan cross-border operations more effectively.