Ukraine: DTA signs with Oman
On 24 July 2019, the Cabinet of Ukraine authorized to sign a Double Taxation Agreement (DTA) with Oman. The agreement contains Dividends rate 5% for at least 20% capital holding; otherwise 10%, Interest rate 10%, and Royalties rate
See MoreUkraine: SFS clarifies treatment of controlled transactions with Bulgaria
On 20 June 2019, the Ukraine State Fiscal Service published a guidance letter No. 2826/6/99-99-15-02-02-15/IPC defining the treatment of transactions with residents of tax Bulgaria, which was removed from the Cabinet tax haven list in April
See MoreDTA between Ukraine and Qatar enters into force
On 9 April 2019, the Double Taxation Agreement (DTA) between Ukraine and Qatar was entered into force and applies from 1 January 2020. The agreement contains Dividends rate 5% for at least 10% capital holding; otherwise 10%, Interest rate
See MoreUkraine: SFS clarifies controlled transactions between a non-resident and its PE in Ukraine
On 19 April 2019, the State Fiscal Service (SFS) of Ukraine published a guidance letter 1723/6/99-99-15-02-02-15/IPK on the treatment of transactions between a non-resident and its permanent establishment (PE) in Ukraine as controlled for transfer
See MoreUkraine: SFS clarifies tax treatment of fines and penalties on non-resident incomes
Recently, the State Financial Service of Ukraine published a guidance letter 1137/6/99-99-15-02-02-15/IPK, which explains the tax treatment of fines and penalties on income paid to non-resident for non-compliance or improper performance of an
See MoreUkraine: SFS issues letter on transfer pricing rules to salaries paid to non-residents
On 29 March 2019, the State Fiscal Service (SFS) of Ukraine issued letter 1358/6/99-99-15-02-15/ІPK on the treatment of salary payments to non-resident persons as controlled for transfer price purposes. The letter states that such payments
See MoreUkraine: Draft law on implementation of BEPS provisions
On 24 October 2018, Ukraine published a draft law on the implementation of some of the recommendation of the OECD/G20 reports on Base Erosion and Profit Shifting (BEPS). The draft law was developed by the Finance Ministry and National Bank supported
See MoreUkraine signs MLI to implement tax treaty related BEPS measures
On 23rd July 2018, Ukrainian Acting Finance Minister Oksana Markarova signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting. The minister expressed that the signing of the MLI makes
See MoreUkraine: President submits draft law on withdrawn capital tax to Parliament
On 4 July 2018, the President of Ukraine presented to Parliament the draft law "On amendments to the Tax Code of Ukraine concerning the tax on the withdrawn capital". The draft law amends the tax law to replace the current corporate income tax
See MoreUkraine issues a letter on refund of overpayment of income tax by non-resident entity
Recently State Fiscal Service released a personal tax consultation letter regarding the refund of tax incorrectly withheld on income derived from Ukraine sources by a non-resident entity. Generally a 15% standard withholding tax rate is applicable
See MoreUkraine extends the list of low-tax jurisdictions
The Cabinet of Ministers of Ukraine has expanded the list of "low-tax" jurisdictions from 65 to 80 countries, adding 17 countries (Morocco, the United Arab Emirates and 15 others) and deleting two countries (French Guiana and Lesotho). The list
See MoreUkraine: SFS publishes guidance letter on definition of related parties
On 5 February 2018, the State Fiscal Service (SFS) published Guidance Letter No. 204/6/99-99-15-02-02-15/IPK of 18 January 2018 clarifying definition of related parties regarding holding ownership of a director who owns the corporate
See MoreUkraine clarifies the definition of controlled transactions for transfer pricing purposes
On 19 January 2018, the State Fiscal Service (SFS) released Guidance Letter No. 119/6 / 99-99-15-02-02-15 / IPK of January 12, 2018, which defines the definition of controlled transactions for cross border transaction purposes. Under the amendments
See MoreUkraine: Parliament adopts the amendment to the Tax Code
On 7 December 2017, the Ukrainian Parliament passed the Law of Ukraine "On Amendments to the Tax Code of Ukraine and Certain Laws of Ukraine on Securing Balance of Budget Revenues in 2018” No. 2245-VIII (“Law”). The law came into force on 1
See MoreUkraine changes in Transfer Pricing Rules from January 1, 2018
On 7 December 2017, the Ukrainian Parliament passed the Law of Ukraine "On Amendments to the Tax Code of Ukraine and Certain Laws of Ukraine on Securing Balance of Budget Revenues in 2018” No. 2245-VIII (“Law”). The law came into force on 1
See MoreUkraine clarifies classification of transactions with a non-resident legal entity
On October 4, 2017, the State Fiscal Service (SFS) published Letter No. 1945/6 / 99-99-15-02-02-15 / IPK of September 13, 2017, which specifies the classification of transactions with a non-resident legal entity for the purpose of transfer
See MoreUkraine: President approves the amending protocol to DTA with Netherlands
On October 6, 2017, the President of Ukraine, Petro Poroshenko, authorized the protocol on amendments to the Taxation and Taxation Agreement with the Netherlands signed in 1995. The protocol will be the first to amend the treaty, and must be
See MoreUkraine and Turkey sign protocol to convention on avoidance of double taxation
On 9 October 2017, a protocol was signed between the Government of Ukraine and the Government of the Republic of Turkey on amendments to the Convention for the avoidance of double taxation and the prevention of tax evasion with regard to taxes on
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