Letter of the State Fiscal Service of Ukraine № 21974/6/99-99-19-02-02-15 from 19.10.2015

A resident who carries out business transactions with a permanent representative office of a non-resident-associated party or a permanent representative office of a non-resident registered in the state (on the territory) included in the List of Low Taxes Jurisdictions, has to submit the Report on controlled transactions. In this case, for the permanent representative office [...]

Letter of the State Fiscal Service of Ukraine № 19545/6/99-99-19-02-02-15 from 14.09.2015

1) Business transactions can be recognized as controlled, if the following condition is fulfilled - the volume of business transactions of the taxpayer with each counterparty, determined according to the accounting rules, exceeds UAH 5 million (net of indirect taxes) for the corresponding tax (reporting) year. 2) If one of the parties to the transaction [...]

Letter of the State Fiscal Service of Ukraine № 18915/6/99-99-19-02-02-15 from 04.09.2015

Transactions with a non-resident independent party are not recognized as being controlled if he is not registered in the low tax jurisdiction, regardless of whether the participant of such non-resident is a resident of the state included in the list. Also, paragraph 140.5 of Article 140 of The Tax Code of Ukraine is not applied [...]