Resolving of practical cases in the field of TP 03.03.2020

During a three-day training session on February 24-26, German Transfer Pricing Experts – Mr. Arnim Hilze of the Federal Central Tax Office (Bonn) and Mr. Guenter Morlock of the Concern Checking Office (Stuttgart), presented the experience of Germany and the EU in the decision of the International Trade Center, experience in this field (OECD provisions) to Ukrainian colleagues. Representatives of the following institutions took part in the training:

– Department of Tax Inspection, Transfer Pricing and International Taxation of the STS of Ukraine;
– Department for Transfer Pricing and International Taxation of the STS big taxpayers office;
– Principal Office of the STS in Kyiv;
– Principal Office of the STS in the Kyiv region;
– Reforms Support Team of the STS of Ukraine;
– Ministry of Finance of Ukraine.

Of particular interest to Ukrainian professionals has been the issue of transactions related to the use or transfer of intangible assets.

In general, during the two and a half days of practical training, the experts considered, in particular, the following key issues:

• Implementation of the concept of development, improvement, support, protection and use of intangible assets (DEMPE);
• Rules for determining the elongation of transactions related to intangible assets on an arm’s length basis;
• Collecting and analyzing information provided by companies and obtained from open sources, as well as through cross-border information exchange and interviewing tools;
• Dispute resolution practice.

The aforementioned seminar allowed the representatives of the STS of Ukraine and the Ministry of Finance to gain additional experience in the relevant field, to know about the examples of Germany and the EU, as well as to discuss their own problematic issues.