Ukraine master file and local file requirements (2026)

What transfer pricing documentation does Ukraine require?

A local file from any taxpayer with controlled transactions, a master file from larger groups, and a country-by-country report from much larger ones. All three are produced on request. Only the controlled-transactions report and the group notification are filed automatically.

Ukraine is not an OECD member but is an Inclusive Framework member, so it implements the three-tier documentation model while running its own thresholds and its own penalty arithmetic.

When is a transaction controlled in Ukraine?

Both money tests have to be met in the same year: annual income above UAH 150 million net of indirect taxes, and transactions with one counterparty above UAH 10 million net of indirect taxes. Clearing one and not the other puts you outside the regime. The OECD transfer pricing country profile for Ukraine^[1] confirms both figures for 2026, with no change yet enacted.

Beyond the money tests, the counterparty has to fall into one of five categories. The net is wider than the OECD baseline, which is the part foreign parents underestimate.

Who counts as a related party in Ukraine?

The definition widened on 1 January 2025, and groups that tested themselves against the old rule can be caught by the new one. The chain-ownership threshold rose from 20% to 25%, and an economic-relatedness test was added alongside it, in a law adopted on 18 June 2024 and published by the Verkhovna Rada^[2].

The economic test is the one worth re-running. A non-resident is now related where a resident's sales to it reach 75% of that non-resident's sales and 50% of the resident's total sales, mirrored for purchases. A single large distributor relationship can create relatedness with no shareholding at all. Re-run the test on your 2025 and 2026 transactions rather than relying on an older firm summary.

What are Ukraine's master file requirements?

The master file is prepared on request, never filed automatically, and only where the group's consolidated income for the financial year before the reporting year reaches the equivalent of EUR 50 million. The tax office may send the request no earlier than 12 months and no later than 36 months after the group's financial year end, and you then have 90 calendar days to submit it.

It is the group-level document: organisational structure, the business, intangibles and intercompany financing. Ninety days sounds generous until you notice that the information sits with the parent, not with the Ukrainian entity, and that the request can arrive three years after the year it covers.

What are Ukraine's local file requirements?

The local file, which Ukraine calls simply the transfer pricing documentation, is produced within 30 calendar days of a tax office request. That request cannot be sent before 1 October of the year following the year in which the controlled transaction took place, so for 2026 transactions the earliest a request can issue is 1 October 2027. It applies to every taxpayer with controlled transactions, whatever the group's size.

The statutory content list is more prescriptive than the OECD minimum. The file has to carry:

• The taxpayer's and the group's ownership structure.
• A description of the group's business activity.
• The terms of each controlled transaction and the parties to it.
• A functional analysis of functions, assets and risks.
• The chosen transfer pricing method and the reason for choosing it.
• The arm's length range and the calculations behind it.
• The business rationale for the transactions.

The arm's length range rests on a benchmarking study, and Ukraine prefers that study to be built from local comparables. Thirty days is not enough time to build one from scratch.

Does Ukraine require country-by-country reporting?

Yes, where the group's total consolidated income for the preceding financial year reaches the equivalent of EUR 750 million. The report is filed within 12 months after the end of the group's financial year, usually by the group parent or an authorised entity. Ukraine also receives data on other groups through automatic exchange as an Inclusive Framework member.

The notification of participation in an international group is a separate thing with a separate date. It goes in with the controlled-transactions report, before 1 October of the following year.

What is filed in Ukraine every year?

Two forms, both electronic, both due before 1 October of the year after the reporting year. For the 2025 financial year that means before 1 October 2026. One is the report on controlled transactions, the other the notification of participation in an international group of companies, per the State Tax Service^[3].

There is a wording discrepancy worth stating plainly. The State Tax Service describes the deadline as before 1 October, which makes 30 September the last day, yet a regional office described the 2025 deadline as 1 October itself. Treat 30 September as the last safe filing day and do not spend the extra day.

What are Ukraine's transfer pricing deadlines?

Two automatic filings on a fixed date, three documents on a clock that starts when the tax office writes. The table below covers reporting in 2026 for the 2025 financial year.

What are the penalties for missing Ukraine's transfer pricing obligations?

Penalties are multiples of the subsistence minimum for an able-bodied person, which is reset every 1 January, so every figure on this page rises next year. For 2026 the subsistence minimum is UAH 3,328 a month, which lifts the top report penalty to UAH 998,400 from UAH 908,400 in 2025, per the State Tax Service^[4].

One relief matters. Under martial law, penalties are waived where the taxpayer meets the obligation within six months after martial law ends. The relief is conditional on actually complying inside that window, so it postpones exposure rather than removing it. The penalty arithmetic for undeclared transactions is set out in the State Tax Service transfer pricing guidance^[5].

What language and currency rules apply in Ukraine?

The statutory documentation language is not confirmed in the verified sources, so this page does not assert one. In practice filings run in Ukrainian and the tax office may ask for a certified Ukrainian translation, but no primary source states the rule.

The currency position is solid. Thresholds and penalties are set in hryvnia and in subsistence minimums. The EUR 50 million and EUR 750 million group figures are equivalents tested against the prior financial year. Exchange rates move, so this page gives no fixed euro or dollar equivalent for the hryvnia thresholds.

How do Ukraine's rules differ from the OECD baseline?

Ukraine applies the three-tier model and follows the OECD guidelines in substance, then adds four edges of its own.

Advance pricing agreements are available to large taxpayers only, in unilateral, bilateral and multilateral form. The term is five years, renewable for a further five, with no fee, under a cabinet resolution of 28 October 2021. For a large taxpayer, that is the only route to certainty, because Ukraine offers no safe harbours at all.

How we help with Ukraine transfer pricing

Ukraine's risk is the gap between a request landing and a file being ready. Thirty days for a local file built on local comparables, ninety for a master file whose data sits with the parent, and a request that can arrive three years after the year it covers. We build the benchmarking and the functional analysis, draft both files to Ukraine's own content list, and keep them current against the 1 October filings and the thresholds you actually cross. See how our transfer pricing software works.

Book a demo to get a Ukraine documentation exposure review before the next request window opens.