Practice area

World TP Reviews

Transfer pricing

allTax is a law firm in Kiev with a team of 12 tax legal practitioners. It provides advice in all areas of tax and focuses on litigation practice, real estate, dispute resolution, commercial and corporate law. Victor Sereda is the managing partner. It has experience advising clients in the agribusiness, IT, energy, oil and gas, real estate and construction and goods trading sectors, to name a few.

The team assisted the Ductum group in a case valued at $3 million. The advisors helped the client to adapt its business structure to comply with the transfer pricing legislative changes introduced in 2018. It became illegal to use Scottish and British partnerships in its structures, so the firm advised on the most suitable jurisdiction for the client’s business.


Asters offers a ‘one-stop shop’ tax service, which covers areas such as corporate tax, transactional tax, tax planning and more. The tax practice is specialised in structuring issues for debt and equity securities issues, lending, providing security, corporate reorganisations, M&A, real estate, joint ventures and more. It has advised numerous multinationals such as UBS Investment Bank, Visa, Siemens Healthcare and many others. Oleksiy Didkovskiy is the managing partner; Alexey Khomyakov and Constantin Solyar are the two tax partners.

Khomyakov is leading the advisory team assisting a multinational client in the healthcare business, on a suitable business structure consistent with Ukraine transfer pricing regulations. This involved assessing alternative ways to supply equipment into Ukraine, optimising the tax, customs, and commercial aspects.

Avellum Partners

Avellum’s tax practice focuses on planning and transactional tax. It has recently diversified its focus to tax disputes, including international and transfer pricing disputes. The practice has also developed expertise in VAT and other indirect taxes. Avellum has experience in tax advisory projects in jurisdiction such as the Netherlands, Luxembourg, the UK, Channel Islands, Cyprus and the USA among others. Mykola Stetsenko is the partner leading the tax practice. 

Avellum represented a client against the tax authorities on its arm’s length transactions with foreign related companies. Avellum challenged the authority’s tax assessment and prepared objections against the tax audit report, examined the transfer pricing documentation for the concerned FY 2015-2016, and was able to prove that client was not required to make changes to its financial results.

Baker McKenzie

Baker McKenzie’s tax practice has eight practitioners and one partner. The team provides advice in international tax planning, transactional tax and tax optimisation for outbound and inbound investment. The firm also advises on transfer pricing matters, such as compliance, the preparation and filing of transfer pricing documentation, assistance during audits and assistance with helping clients to determine the suitable transfer pricing model for their business needs. Hennadiy Voytsitskyi is the tax partner leading the practice, and has more than 20 years of experience in the tax space. 

Voytsitskyi leads the team advising a client in the digital gaming industry in preparing transfer pricing documentation for the FY years 2014, 2015, and 2016 for its intergroup transactions. This required an in-depth understanding of the IT industry. The team are advising another client with determining a possible mechanism to make year-end adjustments concerning transfer pricing.

DLA Piper

DLA Piper’s tax practice in Ukraine has six experienced lawyers with accounting and economics backgrounds. Illya Sverdlov, recently promoted to equity partner, is the head of tax.

The dedicated transfer pricing team has advised large clients such as Alcatel Lucent, Maersk, EPAM and more. The team plays a key role in the firm’s global transfer pricing team, which covers different regions such as North America, Asia Pacific and Europe. DLA Piper’s global policy in project management allows clients to work with other transfer pricing advisers worldwide.

Sverdlov is leading a team advising a French pharmaceutical multinational on compliance with Ukraine regulations. The case involved economic analysis, assessing the specific market conditions and preparing the transfer pricing documentation including the controlled transactions.

Emergex Business Solutions

Emergex Business Solutions is a consulting firm that has provided tax advisory including transfer pricing advice since 2014. The transfer pricing service includes documentation and preparing controlled transaction reports. The transfer pricing team has five practitioners, with a combination of expertise in accounting, legislation, taxation and corporate finance. The firm has experience advising in sectors such as IT, agriculture, logistics, machinery and more. Alina Bakulina heads the transfer pricing department and she specialises in international tax, transfer pricing and international business restructuring.

The firm is assisting a client in preparing transfer pricing documentation and reports on its controlled transactions. This is concerning the client’s intergroup transactions involving importing and reselling in the Ukrainian market. The advisers analysed the essential terms of contracts (terms of payment and delivery, and scope of supply), the risks taken in the controlled and internal comparable transactions, but also the properties of the chemicals the client supplied compared to properties of similar products which are proposed by competitors.


The EMEIA Tax Center at EY is organised as a supranational entity covering the entire Europe, Middle East, India and Africa (EMEIA) region, with its Intercompany Effectiveness and operational transfer pricing practice serving clients’ needs across all jurisdictions.

Led by Oslo-based partner Sveinung Baumann-Larsen, it brings together multi-disciplinary experience and resources focused on IT, accounting, and tax from the entire region in its work. This work covers some of the leading global companies in their respective fields and includes those involved in retail and consumer products, energy and pharmaceuticals, to name but a few.

International Legal Center EUCON

International Legal Center EUCON is a member firm of TPA Global, is a network of independent experts practicing transfer pricing, tax advice and customer services. Viktoriia Kobernyk is the chief counsel of the transfer pricing school, and Yuriy Chebotar is the deputy head of transfer pricing. The transfer pricing team has added new services such as development and adaptation of internal regulations for client’s compliance with the transfer pricing legislation, benchmarking, conducting audits of business transactions and more. 

The transfer pricing team assisted Zepter International Ukraine, an international manufacturer of high-end consumer goods, with producing transfer pricing documentation on controlled transactions. The value of the transaction was more than $20 million.

KM Partners - WTS

WTS Tax Legal Consulting, a member of WTS Global and registered as KM Partners in Ukraine, is a consulting firm specialising in tax, legal and consulting services. It has been providing its legal services since 1999. Its practice provides a full range of services concerning transfer pricing issues, controlled transactions documentation, auditing transfer pricing, appeals on tax assessments and punitive measures and more.

The firm advised Kuehne+Nagel in carrying out a transfer pricing analysis and documentation. The team developed a niche approach dealing with the transactions of royalty fees between the related parties. The process involved cooperation with Derzhovnishinform, a state enterprise that had the relevant data of fees for services/licenses paid by Ukrainian entities abroad, and using the data for benchmarking.


Partner Sergiy Popov heads the tax and legal department, and partner Konstantin Karpushin heads the transfer pricing practice. Karpushin has more than 10 years’ experience in transfer pricing consultation. The firm is a key office in the KPMG international network of more than 155 offices worldwide. Its dedicated transfer pricing team provides advice in all transfer pricing areas and advises more than 500 Ukrainian firms each year. Because of the introduction of the transfer pricing legislation in Azerbaijan and Armenia, large Azerbaijani companies are going to KPMG Ukraine to receive transfer pricing training for their staff. KPMG Ukraine has also won six transfer pricing projects in Azerbaijan and Armenia. 

The firm’s transfer pricing team is advising the Acino Group (a Ukrainian pharmaceutical company) to develop a transfer pricing policy of its group companies. Because of the stringent transfer pricing regulations in the industry, on top of the current transfer pricing rules, the client had to establish a new transfer pricing policy. KPMG proposed a pricing and compensation methodology that is in alignment with the Ukrainian regulations.


PwC Ukraine has been providing full tax legal advice in for more than 25 years, with offices in Kiev, Lviv and Dnipro. Director Olga Trifonova leads the transfer pricing practice and has more than 10 years of experience in transfer pricing. Trifonova’s team covers services such as documentation and reporting, APAs, consulting and training, development of transfer pricing function and policy, and disputes. The team has 126 experts including three equity partners and three directors.

The firm is assisting China National Cereals, Oils and Foodstuffs (COFCO Group) in preparing transfer pricing documentation for its controlled transactions. It analysed the available information on agricultural commodities from public sources to determine the arm’s length pricing for its transfer pricing purposes.

Sayenko Kharenko

Sayenko Kharenko’s tax team of ten practitioners provide a ‘one-stop shop’ service to domestic and international clients. Serhiy Verlanov, partner, is the head of the tax team. The firm has advised clients from sectors such as agriculture, Banking, Chemicals, FMCG, IT, mining, oil and gas and retail. Some of its large clients are Philip Morris Ukraine, Kyivstar and Engelhart Commodities Trading Partners (ECTP) Ukraine.

The firm is advising an agricultural group company in restructuring of its intra-group activities. It is providing complex tax advice concerning the client’s restructuring, and this involved analysing Ukrainian transfer pricing issues and assessing the potential risks in order to propose an improvement of the transfer pricing restructure.