Date: 15 October 2025
Time: 10am - 1pm
Venue: PwC Ukraine office, Kyiv
Event language: Ukrainian
This is a free event.
Registration is required.
The event will not be streamed live.
Registration
We are excited to invite you to attend All about the business rationale: how to justify it and estimate the economic effect, a business meeting with our experts at PwC Ukraine office.
Business rationale tests are a key element of transfer pricing (“TP”) reports, and the lack of business rationale would be the first glaring gap in your defence should you have any disputes with controlling authorities. In the absence of business rationale, tax authorities may challenge the transaction, which would in practice mean that the full amount of expenses may not be tax deductible. With this in mind, justification of business rationale in controlled transactions and transactions with non-residents with specific legal forms or from ‘low-tax’ jurisdictions under para 39.2 Article 39 of the TCU is a key element for TP purposes.
Considering the increasing scrutiny of this matter by controlling authorities, we are pleased to invite you to attend an event focusing on the hot topics of the business rationale in TP. Our experts will share their experience and practical recommendations to help you establish the key factors of your transactions and prepare a high-quality business rationale justification.
In particular, the following topics will be covered:
- The business rationale concept and tax implications if no rationale is demonstrated.
- Justification methodology: collection of evidence, qualitative and quantitative analysis.
- Practical cases: justifying business rationale for various types of transactions, from services to royalty
This event will provide an excellent opportunity to share your views, find fresh solutions and receive valuable recommendations from top experts.
Please join us to gain practical skills regarding the business rationale justification strategy, find out more about the analysis methodology, and learn practical tips for preparing business rationale justification memorandums.
Join us at the meeting where business rationale stops being a mere formality on paper to become a valuable tool for supporting economic viability in your business.
To attend, please follow the link below to register and add any optional questions you would like answered during the event.
Registration
PwC Ukraine experts:
- Olga Trifonova, Partner, Transfer Pricing Leader, PwC Ukraine
- Kateryna Kislitsyna, Director, Transfer Pricing, PwC Ukraine
- Vadym Shyp, Senior Manager, Transfer Pricing practice, PwC Ukraine
- Denys Butylo, Senior Manager, Transfer Pricing practice, PwC Ukraine
We are looking forward to welcoming you at the event.
