Ukraine: STS clarifies on determination of profits attributable to PE
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
See MoreRussia: MLI enters into force
On 1 October 2019, the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into force with respect to the Russian Federation. On 18 June 2019 the Russian Federation deposited
See MoreSwitzerland: Federal Council adopts dispatch on protocol of amendment to DTA with Ukraine
On 9 October 2019, the Swiss Federal Council has adopted the dispatch on the approval of a protocol of amendment to the agreement between Switzerland and Ukraine for the avoidance of double taxation with respect to taxes on income and capital
See MoreRussia enacts legislative changes on Transfer Pricing and MAP
On 29 September 2019, the Russian Government signed a Law no. 325-FZ (Amendments to the Tax Code of the Russian Federation) and published in the Official Gazette. The main amendments relating to transfer pricing are as
See MoreRussia publishes amendments related to corporation tax
On 29 September 2019, the Russian Government signed a Law no. 325-FZ (Amendments to the Tax Code of the Russian Federation) and published in the Official Gazette. The main amendments relating to corporate income tax are as follows: Limitation
See MoreSwitzerland: Federal Council proposes reform of withholding tax regime
On 27 September 2019, the Federal Council of Switzerland issued guidelines on a proposed reform of the Swiss withholding tax (WHT) and stamp tax regimes for indirect investments. The primary objective of the proposal for an exemption from
See MoreUkraine: STS clarifies on controlled transactions report
On 18 September 2019, the State Tax Service (STS) of Ukraine explained about the procedure to file report on controlled transactions for transfer pricing purposes. According to the procedure, representative office that does not meet the conditions
See MoreUkraine increases penalties for tax evasion
On 23 September 2019, the Ukrainian President Volodymyr Zelenskyi has signed Law No. 101-IX on amendments to the Criminal Code of Ukraine and the Criminal Procedure Code of Ukraine, as adopted by the Parliament on 18 September 2019. The Law
See MoreUkraine submits draft law on amendments to the Tax Code to Parliament
On 30 August 2019, the Ukraine has submitted draft law no. 1210 to the Parliament amending the Tax Code on improving tax administration, removing technical and logical mismatches in the tax legislation. The three main areas of the draft law
See MoreUkraine: MOF amends taxpayer’s audit compliance with the arm’s length principle
On 6 September 2019, the Ukrainian Ministry of Finance (MOF) has published Order No. 307 of 16 July 2019 in the official gazette amending Order No. 399 of 30 March 2017. The amendment clarifies the procedures to audit compliance with the arm’s
See MoreRussia: FTS clarifies the application of CUP method
On 2 September 2019, the Federal Tax Service (FTS) of Russia published a Letter No. CA-4-7/17555, about the review of litigation regarding tax control in the field of transfer pricing. For tax purposes, the FTS noted that the courts recognize the
See MoreRussia reduces the Interest rate from September 2019
On 6 September 2019, the Russian Central Bank announced the decision to reduce the key rate from 7.25% to 7.00% with effect from 9 September 2019. For tax purposes, the key rate is important in relation to the safe harbor rates for interest
See MoreDTA between Kosovo and Malta enters into force
On 20 September 2019, the Double Taxation Agreement (DTA) between Kosovo and Malta will enter into force and applies from 1 January
See MoreUkraine issues guidance on transactions between non-resident and its representative offices
On 16 August 2019, the Ministry of Finance issued Order No. 345 providing guidelines on transfer pricing arrangements for transactions between non-residents and their representative offices and permanent establishments in Ukraine. The Order
See MoreRussia updates the CFC notification form
On 1 August 2019, the Federal Tax Service (FTS) has approved the amended CFC and the filing procedure in electronic form with an order of 5 July 2019 No. MMV-7-13 / 338. This regulation extends the list of information on foreign organizations
See MoreUkraine: DTA signs with Singapore
On 16 August 2019, the amending protocol to the Double Taxation Agreement (DTA) between Singapore and Ukraine was signed to update the Exchange of Information Article according to the OECD standard for information exchange,
See MoreNew Zealand: DTA signs with Switzerland
On 8 August 2019, officials from New Zealand and Switzerland signed an amending protocol to update the Double Taxation Agreement (DTA) between them in accordance with BEPS
See MoreRussia reduces the interest rate from July 2019
On 26 July 2019, the Russian Central Bank announced the decision to reduce the key rate from 7.50% to 7.25% with effect from 29 July 2019. For tax purposes, the key rate is important in relation to the safe harbor rates for interest income
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