Ukraine–MNE Tax

Americas

US Internal Revenue Service has suspended tax information exchanges with Russian tax authorities in response to Russian war against Ukraine; no information has been shared since Feb. 24 invasion: David Lawder / Reuters→

April 6, 2022

Africa

OECD releases third batch of transfer pricing country profiles for 28 jurisdictions: OECD→

February 28, 2022

Africa

International tax-related information exchange generates billions in revenue, Global Forum reports

November 17, 2021

The automatic exchange of financial account information between countries is linked directly to at least EUR 3 billion in additional tax revenues; it also has contributed, through voluntary disclosure and other programs, to more than EUR 112 billion in additional tax revenues, according to a November 17 . . .

Europe

Ukraine adopts new procedure on advance pricing agreements for transfer pricing purposes

November 15, 2021

Ivan Shynkarenko, KM Partners, WTS Global, discusses a new procedure applicable to advance pricing agreements for transfer pricing purposes, adopted by Ukraine’s Cabinet of Ministers on October 28, which will become effective on . . .

Asia-Pacific

Ukraine advances tax treaty protocols with Denmark and Qatar

September 30, 2021

Iryna Kalnytska, GOLAW, discusses the Ukraine government’s September 2 publication of a draft tax law ratifying the protocol to the 1996 tax treaty between Ukraine and Denmark, along with the same day signing of a protocol with . . .

Europe

Ukraine Ministry of Finance clarifies general tax consultation on deemed dividends

September 27, 2021

Ivan Shynkarenko, KM Partners, WTS Global, discusses the Ukraine Ministry of Finance’s August 20 approval of, and clarifications to, the general tax consultation covering the application of new rules on deemed dividends’ taxation . . .

Europe

Ukraine clarifies application of transfer pricing rules to transactions with US transparent entities

August 24, 2021

Yuri Nikolaychuk, Rödl & Partner, discusses the Ukraine state tax service’s July 26 ruling concerning the tax implications of transactions between a Ukrainian taxpayer and a US limited liability company based in Texas, confirming that such transactions can be subject both to the transfer pricing rules . . .

Asia-Pacific

Russia’s new double tax treaty policy: the score is 3 to 1

August 4, 2021

Roustam Vakhitov, Crowe Expertiza, analyzes Russia’s new tax treaty policy following the government’s June 7 notice to the Dutch government of Russia’s intent to terminate the double tax treaty between the two countries after a failure to . . .

Antigua and Barbuda

Antigua and Barbuda, Argentina, Russia, South Africa, and Ukraine make progress on meeting international standard on tax transparency and exchange of information in latest peer reviews: OECD→

June 24, 2021

Europe

Ukraine implements mutual agreement procedure for resolving tax disputes

June 10, 2021

Viktoriia Bublichenko, GOLAW, discusses the Ukraine finance ministry’s March 26 decree establishing the detailed order of conduct of the mutual agreement procedure (MAP) for resolving international tax disputes . . .

Digital Economy

Ukraine passes ‘Google tax’ law impacting non-resident digital service providers

June 7, 2021

Iryna Kalnytska, GOLAW, discusses the Ukrainian parliament’s June 3 adoption of a bill introducing the so-called “Google tax,” which directly affects large non-resident companies that provide electronic and digital services in Ukraine . . .

Europe

Ukraine’s new transfer pricing reporting forms

May 24, 2021

Yuri Nikolaychuk, Associate Partner, Rödl & Partner, Kyiv, discusses recent updates to Ukraine’s required transfer pricing documentation . . .

Europe

Ukraine’s new transfer pricing rules expand taxpayer obligations

May 17, 2021

Ivan Shynkarenko, KM Partners, WTS Global, Kyiv, discusses Ukraine’s recent changes to its tax code affecting the transfer pricing . . .

Europe

Ukraine tax authorities adopt new rules for nonresident registration

May 7, 2021

Iryna Kalnytska, GOLAW, discusses Ukrainian tax guidance concerning foreign (non-resident) companies that must register with Ukrainian tax authorities . . .

Asia-Pacific

Japan and Ukraine to negotiate new tax treaty

March 19, 2021

The governments of Japan and Ukraine will begin negotiations for a new income tax treaty, replacing the current one, which entered into force in 1986. . .

Africa

Ukraine, Kenya agree to negotiate tax treaty: Ukrinform→

August 27, 2020

Asia-Pacific

India publishes synthesized text of tax treaty with Ukraine adding MLI changes: Government of India Income Tax Department→

August 19, 2020

Cyprus

Ukraine-Cyprus tax treaty protocol would alter taxation of indirect real estate transfers

December 13, 2019

Leonid Karpov a partner at AC Crowe, Ukraine, discusses the new Ukraine-Cyprus tax treaty protocol, ratified on October 30 by Ukraine’s Parliament. . .

Americas

Ukrainian Parliament ratifies FATCA agreement with US: 112 UA→

October 31, 2019

Asia-Pacific

Singapore, Ukraine tax treaty protocol signed to upgrade information sharing

August 20, 2019

Singapore and Ukraine have signed a tax treaty protocol amending their . . .

Europe

Ukraine to publically release results of first 12 transfer pricing cases to provide guidance to taxpayers: Volodymyr Petrov / KyivPost→

July 10, 2019

Europe

Ukraine considers exit capital tax on dividends paid to shareholders or related parties: Vyacheslav Hnatyuk / KyivPost→

July 2, 2019

Asia-Pacific

BEPS multilateral tax treaty to enter into force for Ukraine

August 8, 2019

Ukraine today deposited with the OECD legal documents ratifying . . .

Europe

Ukraine publishes draft tax and transfer pricing law to implement BEPS provisions

October 29, 2018

Ukraine’s Ministry of Finance and the National Bank of Ukraine have published a draft amendment to the tax code designed to implement international tax and transfer pricing provisions . . .

Europe

Ukraine transfer pricing guidance clarifies treatment of permanent establishments

March 25, 2019

Leonid Karpov, AC Crowe, discusses transfer pricing guidance issued by Ukraine’s tax authority on March 4 addressing transactions between a foreign company and its Ukrainian permanent establishment . . .

Europe

Ukraine ratifies MLI to amend tax treaties

March 4, 2019

Leonid Karpov of AC Crowe, Ukraine writes that on March 1 Ukraine’s Verkhovna Rada adopted the President’s bill concerning the ratification of the MLI . . .

Switzerland and Ukraine sign tax treaty protocol

January 24, 2019

Switzerland and Ukraine today signed a protocol amending . ..

Europe

Luxembourg, Ukraine sign tax treaty protocol

October 6, 2016

Luxembourg and Ukraine have signed a protocol to their 1997 tax treaty, Ukraine’s Ministry of Finance announced . . .

Europe

Ukraine updates transfer pricing rules, adds APA regime: DLA Piper→

January 31, 2018

Europe

UK corporate tax rate will be 17 percent by 2020, Hammond confirms

October 3, 2016

UK Chancellor of the Exchequer Philip Hammond today confirmed that the government will stick to its plan to lower the UK corporate tax rate from 20 percent . . .

Europe

Ukraine signs BEPS MLI to counter tax avoidance by multinationals

July 23, 2018

Ukraine today became the 83rd jurisdiction to sign a multilateral tax treaty designed to swiftly amend bilateral tax treaties to add new provisions countering tax avoidance by multinationals and easing the resolution . . .

Africa

Macau, Mauritius, Ukraine join the ‘inclusive framework on BEPS’ to combat multinational tax avoidance

November 26, 2016

Macau, Mauritius, and Ukraine have joined the ‘inclusive framework on BEPS,’ a group of countries that have pledged to promote the implementation of measures to combat . . .

Europe

Text of Luxembourg, Ukraine tax treaty protocol released

October 19, 2016

The text of the Luxembourg-Ukraine tax treaty protocol, signed September 30, has been released by Luxembourg’s tax administration. The treaty, which would amend the countries’ 1997 tax treaty, provides for a reduction in the . . .

Asia-Pacific

UK proposes to change to BEPS MLI reservations and notifications

April 16, 2018

The UK government today announced proposed changes to the provisional reservations and notifications it made when it signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent . . .

Europe

Ukraine says 13 more countries subject to control under transfer pricing law: Interfax-Ukraine→

January 2, 2018

Europe

Ukraine transfer pricing guidance clarifies treatment of companies that use intermediaries

March 12, 2019

Leonid Karpov, a partner with AC Crowe, Ukraine, discusses new Ukrainian transfer pricing guidance for companies that purchase or sell goods using certain foreign intermediaries . . .

Europe

Ukraine tax authority establishes transfer pricing department: Ukrinform→

January 11, 2019

Europe

UK, Ukraine tax treaty protocol signed, text available

October 24, 2017

The text is available of a protocol to the UK-Ukraine tax treaty, signed by representatives of both countries on October 9. The protocol, which is not yet in force, would amend a double tax treaty signed . . .

Americas

Ukraine, US sign Model 1 FATCA agreement

February 16, 2017

Ukraine and the US have signed a Model 1 FATCA intergovernmental agreement (IGA) according to an . . .

Khaled Al Zaabi on Spanish government proposes digital services tax: “We are seeking assistance with Digital Assets and International Tax Consulting to help Abu Dhabi UAE Oil Company navigate the…” October 24 ,2024

Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024

David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023

Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

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