Letter of the State Fiscal Service of Ukraine № 9013/6/99-99-15-02-02-15 from 26.04.2017

If a non-resident whose form of organization is included in the list approved by the Cabinet of Ministers of Ukraine, has paid corporate tax in his state in the reporting year, business transactions of the taxpayer with such a non-resident are not recognized as controlled (unless there is no other basis for recognizing those transactions [...]

Letter of the State Fiscal Service of Ukraine № 9012/6/99-99-15-02-02-15 from 26.04.2017

If the corporate rights of a resident and a non-resident are owned by the European Bank for Reconstruction and Development in the amount of 20% or more, such parties are recognized as associated entities, transactions between them may be recognized as controlled if they meet the criteria set out in the Tax Code of Ukraine [...]

Letter of the State Fiscal Service of Ukraine №7825/6/99-99-15-02-02-15 from 13.04.2017

Transactions of increasing of the statutory capital by contributing fixed assets reduce the object of taxation of income tax starting from the first depreciation period of such fixed assets, therefore they are recognized as controlled and should be reflected in the report in the reporting period in which the business transaction of increasing of the [...]

Letter of the State Fiscal Service of Ukraine №6857/6/99-99-15-02-02-15 from 03.04.2017

1) Transactions with non-residents whose form of organization is included in the list approved by the Cabinet of Ministers of Ukraine will be recognized as controlled from the date of entry into force of this List. Upon approval of the List, the volume of transactions with such a non-resident will be determined on the basis [...]

Letter of the State Fiscal Service of Ukraine №424/2/99-99-15-02-02-10 from 09.03.2017

Entities can be identified as associated if they meet the criterion set by the Tax Code of Ukraine. In some cases, entities may be proven to be associated if the controlling authority proves such a connection on the basis of facts and circumstances that indicate the existence of control over business decisions of a legal [...]

Letter of the State Fiscal Service of Ukraine №5898/7/99-99-14-01-02-17 from 09.03.2017

Since the transactions of increasing of the statutory capital by contributing fixed assets (equipment) affect the object of taxation of income tax, those transactions fall under the definition of controlled transactions starting from 01.01.2015 in accordance with criterion set by Tax Code of Ukraine. More...

Letter of the State Fiscal Service of Ukraine from 10.02.2017 №2580/6/99-99-15-02-02-15

Despite the fact that the European Bank for Reconstruction and Development is an international financial institution that often cooperates with government officials and municipal enterprises, usiness transactions with mentioned legal entity can be recognized as controlled if they meet the criterion set by the Tax Code of Ukraine. More...

Letter of ГУ the State Fiscal Service of Ukraine in Mykolaivskyi region №316/10/14-29-15-02-20 from 20.01.2017

Since the transactions of increasing of the statutory capital by contributing fixed assets (equipment) affect the object of taxation of income tax, those transactions executed by non-resident member are considered to be controlled in accordance with Article 39 of Tax Code of Ukraine. More...