On 22 November 2016, the Ministry of Finance of
Ukraine announced Ukraine to join OECD Base
Erosion and Profit Shifting (BEPS) Action Plan starting
from 1 January 2017.
According to the Ministry, Ukraine committed to implement four
Plan's Actions, namely:
Action 5: Countering Harmful Tax
Practices More Effectively, Taking into Account Transparency and
Action 6: Preventing the Granting of
Treaty Benefits in Inappropriate Circumstances
Action 12: Mandatory Disclosure
Action 14: Making Dispute Resolution
Mechanisms More Effective
In order of implementation, amendments to the Tax Code of
Ukraine and, in specific cases, to double tax treaties should be
made. At the time, however, there are no respective bills
registered in the Verkhovna Rada of Ukraine. It could be expected,
in light of the Ministry's announcement, that those will be
drafted by the Ministry and brought into the Parliament in
BEPS Action Plan was developed by OECD and G20 and includes
fifteen actions aimed at fighting tax avoidance practices used by
multinational enterprises involving tax base erosion and shifting
of profits to jurisdictions with lower or no taxation. Since 2016,
the Plan has been actively implemented by countries around the
world; 88 countries (including Ukraine) have joined the Plan so
Note that there is still no commitment as to joining system of
automatic exchange of information in tax matters under Common
Reporting Standard (CRS).
We closely monitor the process and will timely update you with
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
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The Common Reporting Standard (CRS) has been initiated by the Organization for Economic Cooperation and Development (OECD) aiming at improving international tax compliance and preventing tax evasion, through the automatic exchange of information between the countries that implement CRS.
Under current law, where a business subject to corporation tax or income tax reallocates an existing asset into its trading stock, the basic rule is that there is a deemed market value disposal of the asset...
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