Dear Sir/Madam,

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”.
Contacts:

Camiel van der Meij, Partner & TLS Leader, camiel.van.der.meij@ua.pwc.com
Slava Vlasov, Partner, Tax and Legal Services, slava.vlasov@ua.pwc.com
Olga Trifonova, Director, Transfer Pricing Group Leader, Tax and Legal Services, olga.trifonova@ua.pwc.com


75 Zhylyanska Street | Kyiv | Tel:  +380 44 354 0404 | Fax: +380 44 354 0790 | pwc.ukraine@ua.pwc.com |  www.pwc.com/ua 

This flash report is produced by PricewaterhouseCoopers’ tax and legal services department. The material contained in this alert is provided for general information purposes only and does not contain a comprehensive analysis of each item described. Before taking (or not taking) any action, readers should seek professional advice specific to their situation. No liability is accepted for acts or omissions taken in reliance upon the contents of this alert.
© 2017 Limited liability company «PricewaterhouseCoopers». All rights reserved. PwC refers to the Ukrainian member firm, and may sometimes refer to the PwC network. Each member firm is a separate legal entity. Please see www.pwc.com/structure for further details.

We will be sending additional Flash reports as issues arise.  If you do not wish to receive these Reports, please advise by return e-mail (pwc.ukraine@ua.pwc.com).  Alternatively, if there is someone else in your company to whom we should send our Alerts, please let us know.

We are pleased to inform that this Flash report is also available in Ukrainian and can be sent to you upon request.
Ми раді повідомити, що цей  Flash report також доступний українською мовою і може бути наданий Вам за запитом.