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 behalf or on the behalf of a related company; and a non-resident is not considered to have a permanent establishment in Ukraine if he carries out economic activities through a resident intermediary, but the provision of agency, trust, commission, and other similar intermediary services for the sale or purchase of goods (works, services) at the expense of in the interests and/or for the benefit of a non-resident is carried out within the framework of the main (normal) activity of the resident and under normal conditions.
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