Online Meeting of the Working Group on International Taxation

The meeting was devoted to the discussion of the international tax tools for transfer pricing controversies, in particular, on the following issues:

1. Advance pricing agreements (APA) – pros and cons for Ukrainian companies and overview OECD ICAP project.

• Overview of APAs: unilateral, bilateral, and multilateral agreements
• Potential benefits for Ukrainian businesses (certainty, reduced disputes, etc.)
• Challenges and limitations in the Ukrainian context

2. Mutual agreement procedure (MAP) – a path to resolving transfer pricing disputes.

• Legal framework and process for Ukrainian taxpayers
• Key advantages and potential drawbacks
• Practical considerations for successful MAP applications

3. Exchange of information – impact on transfer pricing compliance.

• Overview of international exchange of information mechanisms
• Role of Country-by-Country Reporting (CbCR) and spontaneous exchanges
• Implications for Ukrainian taxpayers

4. European best practices and lessons for Ukraine.

• Case studies and experience from European tax authorities
• Practical recommendations for Ukrainian taxpayers and authorities

Speakers: 

• Rezan Ökten, Partner, Dentons (Amsterdam office)
• Valeriya Tarasenko, Tax Advisor, Dentons (Kyiv office)