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Transfer pricing documentation is a key component of the tax strategy for companies engaged in controlled transactions.
Transfer pricing (TP) is a mandatory part of tax compliance for companies engaged in controlled transactions with related parties or non-residents.
According to Article 39 of the Tax Code of Ukraine, businesses are required to prepare annual TP documentation and reports. Failure to comply may result in significant fines and tax audits.
Budfinance Consult offers a full range of transfer pricing services — from analyzing controlled transactions to preparing documentation and supporting clients during audits by the State Tax Service.
We help businesses stay compliant and reduce the risk of financial penalties.

Why Choose Us?

  • 10+ Years of Transfer Pricing Expertise

    We have deep knowledge of the Ukrainian Tax Code and support businesses through even the most complex TP cases.

  • Full-Cycle “Turnkey” ServicesFrom controlled transaction audits to preparing three-tiered documentation — we handle every stage for you.

  • Minimizing Tax Risks
    We prepare well-grounded TP documentation that reduces the risk of penalties and additional tax assessments by the State Tax Service.

  • Confidentiality & Personalized Approach We use only proven methodologies and work under strict NDAs. Your data is securely protected at every stage.

We Cover All Your Transfer Pricing Needs

Transfer Pricing Consulting

One-time or ongoing consultations on identifying controlled transactions, selecting pricing methods, preparing reports, and getting ready for audits.

TP Documentation & Reporting

We prepare a complete package: transaction analysis, market research, profitability calculations, and reporting in compliance with State Tax Service requirements.

Audit of Controlled Transactions

We review your TP documentation for legal compliance, identify potential risks, provide recommendations, and support the submission process.

Transfer Pricing Policy Development

We design an internal TP policy tailored to your business — including analysis, procedures, staff training, and IT integration.

Market Research & Price Range Analysis

We conduct financial and market analysis to determine arm’s length pricing or profitability ranges for use in TP documentation.

Preparation of Three-Tiered Documentation (Local, Master, CbCR)

We prepare documentation in full compliance with OECD standards: Local File, Master File, and Country-by-Country Report.

Legal Support During TP Audits

We protect your interests during tax audits: preparing responses, handling official requests, providing legal justifications, and filing objections to audit reports.

Transfer Pricing Software Solutions

We develop and implement IT tools to automate data collection and processing — improving accuracy, speed, and quality control.

Internal Audit

An independent evaluation of processes, decisions, and resource use to enhance management efficiency and internal controls.
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Stages of Our TP Service Process: How We Work

Initial Consultation
We analyze your business structure, discuss transactions, define the scope of work, and gather initial data. Preliminary diagnostics of controlled transactions and risk assessment are also performed.
Methodology Development & Approach Alignment
We determine applicable TP methods, classify transactions in line with the Tax Code of Ukraine, develop an action plan, and align it with the client.
Preparation of Transfer Pricing Documentation
We prepare a complete package: transaction analysis, profitability calculations, benchmarking, and documentation fully aligned with the requirements of the State Tax Service.
Delivery & Ongoing Support
We provide the finalized documentation, offer consultations, assist with report submission, respond to tax authority inquiries, and support you throughout the process as needed.
GEOGRAPHY OF OUR SERVICES

We work with businesses all over the world

Our clients’ counterparties have been audited in over 15 jurisdictions — including the USA, United Kingdom, Netherlands, Germany, Poland, Italy, China, Turkey, and more.
We have deep expertise in international TP practices and support cross-border transactions with confidence and precision.

Frequently Asked Questions About Transfer Pricing

How long have you been working in the TP field?

We have over 10 years of hands-on experience in transfer pricing support — both in Ukraine and internationally. Our team works with companies across various industries, including multinational groups with complex structures and high volumes of transactions.

How much does TP documentation cost?

The price depends on the number of controlled transactions, your industry, and data complexity. The starting rate is from $1,800. For each case, we provide a personalized commercial offer tailored to your needs.

What’s included in the service cost — and are discounts available?

Our pricing covers the full TP service cycle: transaction analysis, selection of pricing methods, profitability calculations, report preparation, consultations, and support.We strictly follow the requirements of the Tax Code of Ukraine and OECD Guidelines. For projects with a high volume of transactions or multi-year reporting, we offer custom discounts based on the scope.

Can I order only the Controlled Transactions Report?

Yes, absolutely. You can request the report separately — pricing starts from $160. If you decide to order the full documentation later, we’ll apply this amount as a discount toward the total cost.

Is confidentiality guaranteed?

Yes — we ensure full confidentiality of all data provided. Every project is carried out under a signed Non-Disclosure Agreement (NDA), which is a mandatory part of our cooperation. Only the specialists directly involved in your project will have access to your information.

Can I request a review of existing TP documentation?

Yes — we provide audits of your transfer pricing documentation.
Our experts check for compliance with the Tax Code of Ukraine and OECD Guidelines, identify potential risks, and offer practical recommendations for improvement.

What are the penalties for failing to submit TP reports?

Ukrainian tax law imposes significant fines for non-compliance:
  • For not submitting the Report on Controlled Transactions — a fine of 300 living wages (currently over UAH 900,000).
  • For not submitting TP documentation — 3% of the transaction value, capped at 300 living wages.

How to prepare for a TP audit by the State Tax Service?

Start by ensuring you have complete and up-to-date TP documentation for all reporting periods.
Key steps include verifying:
  • proper identification of controlled transactions
  • use of arm’s length methods
  • availability of source documents to support calculations.
We can assist with an internal audit, risk assessment, and preparation of strong, well-structured responses to potential tax authority inquiries.