From 2025, the criteria for recognizing controlled transactions have been updated: details.

Controlled transactions refer to business transactions that may affect the taxable base for corporate income tax (for Dіia City residents – the financial result before taxation). These include transactions made:

• with related non-resident parties, or through the use of another party in the supply chain with no significant functions, assets, or risks;
• through non-resident commissioners;
• with non-residents registered in countries (territories) included in the list of low-tax jurisdictions;
• with non-resident counterparties whose organizational and legal forms are exempt from corporate tax;
• between a non-resident and its permanent representative in Ukraine.

Transactions are considered controlled if they meet both of the following criteria:

From 2025, the criteria for recognizing related persons have been expanded to include economic interdependence (interaction with a counterparty accounts for 75% of total foreign economic activity and 50% of the income/expenses).

New approaches have also been introduced for forming lists of countries (territories) for transfer pricing purposes. The updated lists will apply from January 1, 2025.