The State Tax Service (STS) of Ukraine issued Letter No. 353/ІPK/15-32-05-04-02-15 of 25 September 2019 regarding determination of profits attributable to permanent establishment (PE). Permanent establishment (PE) will be recognized as an independent legal entity regarding its non-resident parent company.
The STS explained that profit attribution to permanent establishment from transactions with its parent company will be determined based on (i) analysis of the PE’s functions, (ii) assets used by the PE, and (iii) distribution of risks between the PE and the parent company.
