On October 16 2015, the Cabinet of Ministers of Ukraine adopted Resolution No. 977-R, which amends the list of low-tax jurisdictions for transfer pricing purposes.
In this context, 'low tax jurisdiction' for transfer pricing purposes refers to a state or territory with a corporate tax rate at least five percentage points lower than Ukraine's general corporate rate of 18%. With the newly adopted resolution, the following countries have been removed from the list of low-tax jurisdictions:
- Switzerland; and
- United Arab Emirates (UAE).
After the removal of the above states, the list of low-tax jurisdictions for transfer pricing purposes includes 65 countries.
As a result of the removal of the above jurisdictions from the low-tax list, operations with companies registered in any of these states will no longer be considered as regulated operations for transfer pricing control purposes. These amendments are significant for the Ukrainian business sector and will improve the cooperation with many popular jurisdictions, particularly Switzerland, Luxemburg, UAE and Singapore.
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