On 27 December, 2017 the Cabinet of Ministers of Ukraine amended the list of low-tax jurisdictions which is used for transfer pricing purposes. Per Ukrainian tax rules, in order for a jurisdiction to be considered a low-tax one, its corporate income tax rate should be lower than the Ukrainian one by 5 percentage points (or more). Additionally, countries which have not concluded exchange of information agreements with Ukraine as well as countries whose competent authorities do not guarantee timely exchange of tax and financial information are also included in the list.
The list was expanded to include new jurisdictions such as Estonia, Malta, the United Arab Emirates, Singapore, Hungary and Georgia.
The new decree with the amended list of low-tax jurisdictions was published in the official newspaper “Uriadovy Kurier” on 29 December 2017 and came into force on 1 January 2018.
Companies operating in Ukraine are strongly advised to evaluate any potential impact and revise their current business structures if affected.
The full list of low tax jurisdictions now includes 85 jurisdictions and is available at the following link: https://qdpro.com.ua/export/document/61909