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Ukraine approved the amendments regarding the BEPS plan


The Government of Ukraine announced the adoption by Parliament the bills to improve tax administration and the implementation of several measures from the action plan regarding domestic tax base erosion and profit shifting (BEPS).

Key measures include the introduction of rules on controlled foreign companies and requirements for the disclosure of information about them, along with a corporate income tax return. It is also planned to introduce transfer pricing rules, including the distribution of functions, risks and intangible assets in a group of companies, and rules regarding the indirect sale of real estate.

Bills also include changes in thin capitalization rules – reducing the earnings before interest, taxes, depreciation and amortization (EBITDA) from 50% to 30% in relation to deductible interest and eliminating the debt to equity ratio of 3.5 to 1, respectively.

The parliament also proposes updating tax rules for permanent missions, including the rule against fragmentation (separation of contracts) and the addition of a general test for the main goal when applying double taxation avoidance agreements.


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