Starting from 1 October: existing approach to commodity transactions codified
12/11/25
Effective from October 1, 2025, the Law of Ukraine No. 4536-IX (hereinafter – the “Law”) entered into force, clarifying the application of the term “quoted prices” and the rules for determining the arm’s length nature of prices in controlled commodity transactions.
In particular, the Law establishes that the term “quoted prices” shall be applied for the purposes of Article 39 of the Tax Code of Ukraine (hereinafter – the “TCU”) starting from the tax periods beginning on January 1, 2021.
Therefore, in the view of the State Tax Service of Ukraine, for transactions performed prior to this date, the general provisions of the TCU apply. These provisions allowed the use of publicly available data sources—such as exchange quotations, price indicators, and analytical materials — to support that controlled transactions were performed at arm’s length.
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