Ukraine: SFS clarifies PE rule for non-residents for tax purposes
On 12 October 2021, the Ukrainian State Fiscal Service (SFS) has clarified that a non-resident company considers as a permanent establishment (PE) if the company enters into agreements and carries out economic activities in Ukraine on its own
See MoreUkraine: STS clarifies about taxation of dividends received
On 3 September 2021, the Ukrainian State Tax Service (STS) has clarified that in case of dividends received by a legal entity from another legal entity under a simplified tax regime, the dividends that have not been taxed under the Tax Code of
See MoreUkraine: STS clarifies the controlled transactions criteria for TP purposes
Recently, the State Tax Service (STS) has clarified the criteria for classifying transactions between related parties (Ukrainian residents and non-residents) as controlled for transfer pricing (TP) purposes. Under Ukrainian transfer pricing
See MoreUkraine: MOF approves three Orders on transfer pricing and other taxes
On 20 August 2021, the Ukraine Ministry of Finance announced the issuance of three orders that approve tax clarifications/consultations on: Issues of taxation of income of non-residents, which are equated to dividends (Order №
See MoreUkraine: National Bank increases the interest rate from September 2021
On 9 September 2021, the National Bank of Ukraine has decided to increase its key policy rate from 8% to 8.5% per annum with effect from 10 September 2021. The interest rate has a tax effect on the late tax payment interest and penalties which is
See MoreOECD: Ukraine commits to automatic exchange of financial account information
On 30 August 2021 the OECD announced that Ukraine is committed to implementing the international Standard for Automatic Exchange of Financial Account Information in Tax Matters (AEOI) by 2023. More than a hundred member countries of the OECD's
See MoreUkraine issues taxation of income of non-residents
On 27 Aug 2021, the Ukrainian Ministry of Finance has issued Order No. 480 regarding the taxation of income of non-residents, which are equated to dividends. The Order provides clarification on the application of the new rules of taxation of income
See MoreUkraine: STS releases guidance letter on tax treaty requirements under CFC rules
On 12 July 2021, the State Tax Service (STS) has issued a guidance letter 2712/IPK/ 99-00-21-02-02-06 which clarifies tax treaty requirements under CFC rules. The guidance letter clarifies that from 1 January 2022 CFC profits may be exempt from
See MoreUkraine: National Bank increases the interest rate from July 2021
On 22 July 2021, the National Bank of Ukraine has decided to increase its key policy rate from 7.5% to 8% per annum with effect from 23 July 2021. The interest rate has a tax effect on the late tax payment interest and
See MoreUkraine issues draft laws on tax incentives for industrial park
Ukraine has issued Draft Law 5688 on 22 June 2021, and Draft Law 5688-1 on 7 July 2021 ‘on Amendments to the Tax Code of Ukraine to create favorable conditions for attracting large-scale investment in the industrial park’. The Draft Law
See MoreUkraine: National Bank increases the interest rate from April 2021
On 15 April 2021, the National Bank of Ukraine has decided to increase its key policy rate from 6.5% to 7.5% per annum with effect from 16 April 2021. The interest rate has a tax effect on the late tax payment interest and
See MoreUkraine: National Bank increases the interest rate from March 2021
On 4 March 2021, the National Bank of Ukraine has decided to increase its key policy rate from 6% to 6.5% per annum with effect from 5 March 2021. The interest rate has a tax effect on the late tax payment interest and
See MoreUkraine: MOF approves the procedure for submitting CbC report
On 19 February 2021, the Ukrainian Ministry of Finance (MOF) has issued a press release where they clarify the procedure for submitting Country-by-Country (CbC) report. The Order of the Ministry of Finance No. 764 dated 14 December 2020, which
See MoreUkraine: MOF develops a regulatory framework for the execution of the BEPS
On 20 October 2020, the Ukrainian Ministry of Finance (MOF) has issued a press release regarding Implementation of the Law No 466 in Part of the BEPS Plan. MOF stated that they will approve all necessary regulations on the implementation of the
See MoreUkraine introduces loss carry-back provisions
On 15 September 2020, The Ukrainian Parliament has accepted for consideration Draft Bill No. 4101, which introduces loss carry-back provisions. The loss carry-back provisions would allow taxpayers to carry back losses up to 5 years. The Bill
See MoreUkraine: SFS releases guidance letter on new CFC rules
On 17 August 2020, the Ukraine State Fiscal Service (SFS) has issued a guidance letter 3380/IPK/99-00-05-05-02-09, which clarifies the taxation of profits of controlled foreign companies (CFCs). In Ukraine, the CFC rule will be applicable from 1
See MoreUkraine: Ukraine: National Bank reduces the interest rate from June 2020
On 11 June 2020, the National Bank of Ukraine has decided to reduce its key policy rate from 8% to 6% per annum with effect from 12 June 2020. The interest rate has a tax effect on the late tax payment interest and
See MoreUkraine updates its blacklist adding Panama
On 27 May 2020, the Ukrainian Cabinet of Ministers has published Order No. 582-r updating the blacklist of non-cooperative tax jurisdictions. Through the Order, the Cabinet of Ministers has added Panama to the list. Pursuant to an explanatory note,
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