On 16 January 2020, the Parliament of Ukraine adopted the Anti-BEPS Law. The Anti-BEPS Law introduces a number of measures to combat tax base erosion and profit shifting with the CFC Rules being amongst the most significant novelties. To this end, the CFC Rules enable taxation of controlled foreign entities' income pertaining to Ukrainian residents through their ownership interest or de facto control. The CFC Rules establish specific provisions on taxation, reporting, exemptions, tax audits, and liability for tax payers. Noteworthy, the attributable CFC's income should be exempted from taxation in Ukraine if, inter alia, total income for the reporting period of all CFCs of a taxpayer is EUR 2 million or less. The Anti-BEPS Law is currently pending signing by the President of Ukraine with the CFC Rules being scheduled to enter into force on 1 January 2021.
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