On 1 January 2022, the CFC rules became effective in Ukraine. For the novelty of the concept and the imperfections of the underlying legislation, many provisions of the applicable CFC rules call for clarification, elaboration, or further guidance.
In this context, on 2 May 2023, the Parliament of Ukraine passed – in the first (of typically two) readings – Bill No. 8137 “On Amendments to the Tax Code of Ukraine with respect to Enhancement of the Taxation of Controlled Foreign Companies” (“Amending Bill”), aimed at addressing most pressing issues pertaining to the application and interpretation of the CFC rules.

On 15 June 2021, the Parliament of Ukraine adopted a law commonly referred to as the Tax Amnesty Law1 (“Law”), which introduces voluntary disclosure program with respect to unreported taxable income and assets. On 21 July 2021, the Law entered into force. By its terms, the tax amnesty will be available from 1 September 2021.

On 15 June 2021, the Parliament of Ukraine adopted a law commonly referred to as the Tax Amnesty Law1 (“Law”), which introduces voluntary disclosure program with respect to unreported taxable income and assets. On 21 July 2021, the Law entered into force. By its terms, the tax amnesty will be available from 1 September 2021.

In brief On 25 February 2021, the President of Ukraine submitted to the Parliament of Ukraine Bill No. 5153 “On Amendments to the Tax Code of Ukraine on Stimulating the Regularization of Income and Improving Tax Culture of Citizens by Introducing Voluntary Disclosure by Individuals of Their Assets and Payment…

Foreign entities operating in the territory of Ukraine, including those who already have a representative office in Ukraine, must register with the tax authorities by 31 March 2021.

On 23 May 2020, the Law of Ukraine “On Amendments to the Tax Code of Ukraine Purposed to Improve the Administration of Taxes, Eliminate Technical and Logical Inconsistencies in the Tax Legislation” (“Anti-BEPS Law”) became effective with certain provisions being phased out.

At the same time, certain provisions of the Anti-BEPS Law have called for the extension of their entry into force or elaboration thereof.

To this end, on 14 July 2020, the Parliament of Ukraine passed Law of Ukraine No. 786-IX “On Amendments to the Tax Code of Ukraine with respect to Functioning of the Electronic Cabinet and Simplification of Work of Private Entrepreneurs”, which entered into force on 8 August 2020.

In addition, on 17 December 2020, the Parliament of Ukraine adopted the Law of Ukraine “On Amendments to the Tax Code of Ukraine and Other Laws of Ukraine to Ensure the Collection of Data and Information Required for Reporting of Certain Income Subject to Taxation” (“Amending Law”).

On 1 January 2021, the Amending Law became effective.

In brief On 16 December 2020, Verkhovna Rada (Parliament) of Ukraine ratified the Protocol amending the 1997 Tax Treaty between Ukraine and Austria (“Protocol”). Key takeaways Depending on how quickly Ukraine and Austria exchange diplomatic notes, the changes should affect your business in 2022. Thus, we recommend reassessing your current…

In brief On 23 May 2020, the Law of Ukraine “On Amendments to the Tax Code of Ukraine Purposed to Improve the Administration of Taxes, Eliminate Technical and Logical Inconsistencies in the Tax Legislation” (‘Anti-BEPS Law’) became effective with certain provisions being phased out. At the same time, certain provisions…

On 23 May 2020, the Law of Ukraine “On Amendments to the Tax Code of Ukraine Purposed to Improve the Administration of Taxes, Eliminate Technical and Logical Inconsistencies in the Tax Legislation” (‘Anti-BEPS Law’) became effective with certain provisions being phased out.

At the same time, certain provisions of the Anti-BEPS Law have called for the extension of their entry into force or elaboration thereof.

Separately, the President of Ukraine referred to the Cabinet of Ministers with a number of recommendations purposed to enhance the Anti-BEPS Law concerning, inter alia, the CFC Rules, protection of data reported by taxpayers and obtained from the foreign jurisdictions.

To this end, on 14 July 2020, the Parliament of Ukraine passed Law No. 786-IX “On Amendments to the Tax Code of Ukraine with respect to Functioning of the Electronic Cabinet and Simplification of Work of Private Entrepreneurs” (‘Amending Law’). On 8 August 2020, the Amending Law entered into force.