044 496 69 49
UA

OLEG IVCHENKO

UKRAINIAN ASSOCIATION OF VALUATION SPECIALISTS (PUAVS)
Authorized by the
WORLD ASSOCIATION OF VALUATION ORGANIZATIONS (WAVO)

Over 15 years of experience
Hello,
I’m Oleh Ivchenko — a certified valuer, founder and managing director of Pareto Consulting Group and the Wise Group (a patent and legal advisory firm). With over 15 years of hands-on experience in valuing companies, assets, enterprises, and intangible property of any complexity, I deliver insights at the intersection of finance, law, and analytics.

Clients come to me when the stakes are high — when results must be accurate, defensible, and trusted by international auditors, banks, and regulatory bodies. My expertise includes business valuation, transfer pricing advisory, CFC reporting, IFRS-compliant audit support, and tax consulting focused on risk mitigation and legal optimization.

This website is my personal platform to communicate openly with business leaders. If you're looking for an expert who sees more than just numbers — someone who understands context, strategy, and value — you're in the right place.

Trust expertise. Move forward with confidence.
Get to Know Me Better

Our services

  • Preparation of TRANSFER PRICING DOCUMENTATION & REPORTS

  • Development and Implementation of TRANSFER PRICING POLICY

  • LEGAL SUPPORT During TAX AUDITS
    and TP DISPUTES

  • Аудит контрольованих операцій — перевірка дотримання принципу витягнутої руки у трансфертному ціноутворенні

    AUDIT of CONTROLLED
    TRANSACTIONS

  • Складання трирівневої документації з трансфертного ціноутворення відповідно до вимог OECD та законодавства України

    Preparation of THREE-TIERED TRANSFER
    PRICING DOCUMENTATION

When your business needs transfer pricing services?

  • When the company conducts controlled transactions with non-residents

  • During the preparation of transfer pricing documentation and reports

  • Market research and arm’s length range analysis for TP purposes

  • In case of group restructuring or changes in the business model

And for any other transfer pricing needs your business may have

Submit a request

What is transfer pricing (TP)?

Transfer pricing (TP) is a system for controlling prices in financial transactions between related parties — particularly within multinational groups and cross-border operations with non-residents.
Its main goal is to prevent profit shifting and ensure taxation according to the arm’s length principle, so that companies pay taxes where economic value is actually created.

Who needs transfer pricing services?

Transfer pricing regulations apply to companies that:
  • conduct controlled transactions with non-resident entities;
  • have business relationships with offshore or low-tax jurisdictions;
  • are members of multinational enterprise (MNE) groups;
  • prepare TP documentation for submission to the tax authorities;
  • or undergo tax audits related to transfer pricing compliance.
Our TP services help such businesses stay compliant, reduce risks, and avoid tax penalties.

What changes to transfer pricing rules apply in Ukraine from 2025?

According to the updated provisions of the Ukrainian Tax Code (effective 2025):
  • The profitability range has been narrowed — companies must use the weighted average within the arm’s length range.
  • Three-tiered TP documentation (Master File, Local File, Country-by-Country Report) becomes mandatory for all entities that are part of an MNE group, regardless of transaction volume.
  • A new Country-by-Country (CbC) report is introduced, disclosing profit and tax allocation within MNE structures.
  • Criteria for controlled transactions have been revised — not only transaction volume but also functional linkage between entities is now considered.
  • Penalties for non-submission or inaccurate reporting have increased (up to 300 minimum wages).
  • Retention period for TP documentation is now set at a minimum of seven years.

How are controlled transactions defined??

A transaction is considered controlled if it meets one or more of the following criteria:
  • conducted with a non-resident registered in a low-tax jurisdiction;
  • involves related parties (ownership or control of 20% or more);
  • total annual transaction volume exceeds UAH 10 million (excluding VAT);
  • one of the parties applies a special tax regime or enjoys tax benefits.

What are the consequences of non-compliance with TP rules?

Failure to comply with transfer pricing regulations may result in:
  • additional tax assessments and adjustments;
  • penalties for late or missing reports;
  • reputational risks with banks, investors, and auditors;
  • potential criminal proceedings in cases of intentional tax evasion.
Proper TP management and documentation protect your business from these risks and demonstrate fiscal transparency.

Why choose our transfer pricing team?

  • We operate strictly in accordance with the Ukrainian Tax Code and OECD BEPS standards.
  • Our TP reports are accepted by the State Tax Service and external auditors.
  • Over 10 years of experience in transfer pricing and tax consulting.
  • Full confidentiality, professionalism, and legal protection for every client.

Our case studies

Business Planning Case

DEVELOPMENT OF A CONSTRUCTION PROJECT FOR A PLANT WITH 10 FURNACES FOR CBF FIBER PRODUCTION IN EUROPE
Learn more

Fixed Asset Valuation Case

VALUATION OF A 1974 CESSNA 172M AIRCRAFT TO DETERMINE ITS MARKET VALUE FOR A PURCHASE AND SALE AGREEMENT
Learn more

Financial Investment Valuation Case

SHARE VALUATION FOR A PUBLIC JOINT STOCK COMPANY TO DETERMINE THEIR FAIR MARKET VALUE
Learn more
Explore more projects

Customer Video Testimonials

What else we offer?

Additional projects and experience
Logo of Pareto Consulting Group — asset valuation, business planning, and grant project support

Pareto Consulting Group

Valuation of all types of assets, business planning, and support for grant-funded projects
Logo of Wise Group — trademark, copyright, and patent registration services

Wise Group – Patent & Legal Firm

Trademark, copyright, and patent registration, as well as protection of other intellectual property assets.
Logo of TCO Audit Project — transfer pricing, CFC reporting, IFRS and tax consulting services

TCO Audit Project

Transfer pricing services, CFC reporting, IFRS financial advisory, and tax consulting.