Mykola Mishyn spoke at the BEPS Forum of the foreign companies' owners

Last week, Mykola Mishyn, Partner, Head of Transfer Pricing Practice at A1 Consulting, spoke at the BEPS Forum of the foreign companies' owners that was organized by the International Advisers Association.
He shared his experiences and vision on the panel "Transfer Pricing and Disputes on Business Purpose".
Mykola Mishyn presented his expert opinion on the draft Procedure for establishing compliance of the conditions of controlled transactions with raw materials based on the "at arm's length" principle. "Taking into account the possible changes to the Tax Code of Ukraine, we expect this order to enter into force as of January 1, 2023. In general, it contains important and useful methodological approaches. However, business should expect fiscalization of regulatory authorities to the control over such goods", Mykola said.
TP remains one of the most discussed topics for the companies involved in foreign economic operations. No wonder, the panel attracted the attention of many experts who participated in the Forum.
The panel participants discussed current burning issues, including justification of the business purpose in the controlled transactions of past periods, the risks for payers in royalty payments, as well as interest on loans. Promising novels included constructive dividends, commodities, and master files.