We are pleased to provide a copy of our new Flash report concerning the list of organizational and legal forms of non-residents (can be found in the attachment).
On 4 July 2017, the Cabinet of Ministers of Ukraine (further – the CMU) approved a list of organizational and legal forms of non-residents (further – OLF list) that is to be used for transfer pricing purposes.
Transactions with these non-resident may qualify as controlled (i.e. subject to Ukrainian transfer pricing rules) based on criteria specified in para «г» para 39.2.1.1. of Tax Code of Ukraine.
Please refer to the OLF list in the attachment.
The CMU's Order comes into effect on the date of its publication.
Please consider the impact of these regulations on your business.
*The Order of the Cabinet of Ministry of Ukraine #480 from 4 July 2017 "On Approval of the List of Organizational and Legal Forms of Non-Residents Paying No Income Tax (Corporate Tax), Including Tax on Income Received outside the State of Registration of Such Non-Residents, and/or Are Not Tax Residents of the State in which They Are Registered as Legal Entities Person".