Ukraine Corporate Tax Guide

Page 1

Worldwide Corporate Tax Guide 2022

Kyiv GMT

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Business Tax Advisory, International Tax and Transaction Services –International Corporate Tax Advisory and International Tax and Transaction Services – Transaction Tax Advisory

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International Tax and Transaction Services – Transfer Pricing

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Global Compliance and Reporting

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 Vladimir Kotenko +380 (44) 490-3006

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Indirect Tax – Customs and International Trade

Anton Melnyk

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 Borys Lobovyk

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Bogdan Malniev +380 (44) 499-3356 Mobile: +380 (67) 231-5330 Email: bogdan.malniev@ua.ey.com

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The information in this chapter is current as of 1 January 2022. Special tax rules have been enacted for the period of martial law in Ukraine, which are briefly summarized in Section G. Martial law was introduced in Ukraine on 24 February 2022 by the Decree of the President of Ukraine “On Martial Law in Ukraine” No. 64/2022, duly approved by Verkhovna Rada of Ukraine.

A. At a glance

Corporate Income Tax Rate (%) 18 (a)

Capital Gains Tax Rate (%) 18

Branch Tax Rate (%) 18

Withholding Tax (%)

Dividends 15

Interest 0/5/15 (b)(c)

Royalties 15

Freight 6

Income from Discount Bonds 18 (d)

Insurance 0/4/12 (e)

In-kind Ukrainian-Source Income 15 (f)

Other Ukrainian-Source Income 15 (g)

Branch Remittance Tax 0

Net Operating Losses (Years)

Carryback 0 Carryforward Unlimited (h)

(a) Special tax rates exist for insurance and lottery companies. (b) The following interest is exempt from withholding tax:

• Interest and income (discounts) received by nonresidents from state securi ties, municipal bonds or debt securities if these instruments are secured by state or municipal guarantees

• Other income from state securities, paid by the Ministry of Finance of Ukraine

• Interest payments to nonresidents on loans received by the state or to a municipal budget if they are reflected in the state or municipal budget or in the budget of the National Bank of Ukraine

• Interest on loans obtained by business entities if fulfillment of these loans is secured by state or municipal guarantees

(c) Withholding tax exemption is available for interest paid to nonresident lend ers on loans financed through the issuance of debt securities (interest on loan participation notes) on a stock exchange outside Ukraine. The following conditions apply:

• If the loan is obtained before 2017, the exemption applies if the funds provided as a loan were raised with the aim to provide (directly or indi rectly) a loan to a resident.

• If the loan is obtained in 2017 or 2018, the exemption applies if all of the following conditions are satisfied:

The qualifying debt securities are listed on a recognized stock exchange (currently, the list contains 21 stock exchanges in various jurisdictions, including the New York Stock Exchange, London Stock Exchange, Deutsche Boerse AG, Japan Exchange Group, Inc. and Singapore Exchange).

The funds provided as a loan were raised with the aim to provide (directly or indirectly) a loan to a resident.

The foreign interest recipient is not resident in a low-tax or non-transparent jurisdiction (see Transfer pricing in Section E for more details).

A reduced 5% withholding tax rate applies to interest from loans obtained from 2019 onward, subject to similar conditions.

(d) The tax base is calculated as the difference between the nominal value of the discount bonds and the acquisition value (purchase price) of the bonds on the primary or secondary stock market. Exemptions apply (see footnote [b] above).

(e) In essence, the tax on insurance payments is not a withholding tax, because the tax on insurance payments is not withheld from the payments remitted to the nonresident recipient, but is paid at the expense of the Ukrainian company

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making the payments (that is, the economic burden of paying the tax is borne by the Ukrainian party).

The 0% rate applies to the following:

• Insurance and reinsurance payments to financially reliable nonresidents

• Insurance payments with respect to civil aviation passenger transportation

• Insurance payments to nonresident individuals under mandatory insurance agreements

• Insurance payments under Green Card insurance agreements (mandatory third-party liability insurance for car owners of states participating in the Green Card system)

• Reinsurance payments with respect to mandatory civil liability insurance of nuclear facility operators

The 4% rate applies to insurance payments to nonresidents under insurance agreements covering risks outside Ukraine (subject to exceptions). The stan dard 12% rate applies in all other cases.

(f) Payment of in-kind Ukrainian-source income is subject to 15% withholding tax under a gross-up formula provided in the Tax Code.

(g) Profit from disposal of state securities, municipal bonds or debt securities received by nonresidents is exempt from withholding tax if these instruments are secured by state or municipal guarantees (except for profit of nonresi dents from low-tax jurisdictions).

(h) Special rules apply to large taxpayers and to transfers of losses in the course of reorganizations. For further details, see Relief for losses in Section C.

B. Taxes on corporate income and gains

Corporate profit tax. Ukrainian legal entities (except for non profit organizations) are subject to corporate profit tax (CPT) on their worldwide income and gains. Foreign legal entities (except for organizations with diplomatic privileges or immunities) are subject to CPT if they receive Ukrainian-source income. CPT also applies to nonresidents who conduct business activity in Ukraine through a permanent establishment (PE) and/or receive Ukrainian-source income, and other nonresidents obliged to pay CPT in Ukraine.

Beginning 1 January 2022, foreign companies having a place of management in Ukraine are included in the list of CPT payers and taxed on their Ukraine-source income.

PEs. The Ukrainian tax law envisages that a PE could arise for a nonresident in Ukraine by virtue of a fixed place of business, provision of services through personnel, construction site and related supervisory activity, and dependent agent’s activity. The 2020 tax reform law has introduced several anti-Base Erosion and Profit Shifting (BEPS) initiatives, including changes to the Ukrainian PE rules. These changes extended and specified the scope of PE, introduced new rules for tax registration and taxa tion of nonresidents carrying out activity in Ukraine through PEs, and granted to the Ukrainian tax authorities additional powers with respect to PE detection and related tax administration, in cluding forceful tax registration of nonresidents, unscheduled tax audits, and tax seizure of nonresidents’ property located in Ukraine.

Rates of tax. The CPT rate is 18%.

Temporary CPT exemptions are available for the following cases, subject to qualifying conditions:

• For the aircraft industry: until 1 January 2025

• For large investment projects: within five consecutive years until 1 January 2035

• For profit of business entities engaged exclusively in the manu facturing of electrical vehicles, engines, batteries, and charges

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for electric vehicles as well as of some other qualifying means of transportation: until 31 December 2035

• For agricultural producers engaged in breeding, rearing and production of poultry, ostriches and quails, except for rearing chickens, and chicken meat and eggs production: until 1 January 2027

A special tax regime is available for the information technology (IT) industry (see Diia City Regime in Section G).

Application of the simplified tax regime with 2% turnover tax is allowed for all taxpayers for the period of martial law in Ukraine (see Section G).

Capital gains. Capital gains are included in the pretax financial result and generally taxed at the regular CPT rate.

Special tax rules apply to capital gains derived from trading in securities. Profits from trading in securities are included in tax able profit. Losses from trading in securities, including losses on security revaluations, can be carried forward indefinitely to offset future income from such trading.

Starting 1 January 2021, new rules apply to capital gains from qualifying foreign-to-foreign direct and indirect transfers of realestate-rich Ukrainian companies. Nonresident buyers must regis ter with the Ukrainian tax authorities and administer withholding tax on such transfers. The applicable withholding tax rate is 15%, subject to treaty protection.

Administration. Under the general rule, taxpayers must report CPT quarterly on a cumulative basis. Annual CPT reporting is available for the following taxpayers:

• Newly incorporated companies

• Agricultural producers

• Companies with annual income, net of indirect taxes, of less than UAH40 million (approximately USD1,367,000)

Taxpayers that file only an annual return must submit it within 60 days after the year-end. If a taxpayer files tax returns quar terly, the quarterly tax returns must be submitted within 40 days after the end of the quarter, and the final annual return must be submitted within 60 days after the end of the year. Tax is payable within 10 days after the deadline for submitting the tax return.

Dividends. A company distributing dividends to its shareholders must pay an 18% advance corporate profit tax (ACPT) on the positive difference between the amount of dividends and taxable profit for the reporting year for which dividends are paid, pro vided that the tax liability for the year is settled (if unsettled, ACPT is levied on the whole amount of dividends). The tax is paid either before or at the moment of the dividend distribution. The ACPT is paid at the expense of the dividend payer and does not decrease the amount of dividends due to shareholders. In general, ACPT can be offset against the CPT liability of the taxpayer in the current period and subsequent periods.

Exemption from ACPT on dividends applies to the following dividends:

• Dividends paid to individuals

• Dividends paid by joint investment vehicles

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• Dividends paid to shareholders of the taxpayer’s parent com pany, up to the amount of dividends received by the parent company from third companies

• Dividends paid to companies whose profits are exempt from tax, up to the amount of such exempt profits in the period for which dividends are paid

Ukrainian CPT payers do not include in their taxable profit divi dends received from other Ukrainian CPT payers (except for collective investment vehicles and companies whose profits are exempt from tax, up to the amount of such exempt profits). Payments of dividends are not deductible for CPT purposes.

Dividends distributed to nonresidents are subject to withholding tax at a rate of 15% (to be calculated under a gross-up formula if distributed in-kind), unless an applicable double tax treaty pro vides otherwise.

The following payments are considered equivalent to dividends:

• Any monetary or in-kind payments made by legal entities to their shareholders in relation to the distribution of part of or all their net profit

• Payments for securities (corporate rights) to related and other qualifying nonresidents in transactions falling under transferpricing control in the amount exceeding the arm’s-length level

• Value of goods (services) purchased from related and other qualifying nonresidents in transactions falling under transferpricing control in the amount exceeding the arm’s-length level

• Understatement of the value of goods (services) supplied to related and other qualifying nonresidents in transactions falling under transfer-pricing control in the amount below the arm’slength level

• Monetary or in-kind payments to nonresident shareholders in relation to reductions of share capital, buy-backs of the corpo rate rights, withdrawals from shareholding or similar transac tions between legal entities and their shareholders in the amount resulting in decrease of the retained earnings of the legal entity

The second through fifth payments above are considered equiva lent to dividends starting 1 January 2021 and are excluded from the scope of ACPT.

The application of double tax treaty protection to payments con sidered to be equivalent to dividends should be analyzed on a case-by-case basis.

Foreign tax relief. Ukrainian companies may credit foreign tax paid with respect to foreign-source profits against Ukrainian tax imposed on the same income, up to the amount of such Ukrainian tax. The credit is granted only if the taxpayer submits a written confirmation from the tax authorities of the foreign country that certifies payment of the foreign tax.

C. Determination of taxable profit

General. Taxable profit is defined as the financial result before tax, determined under Ukrainian accounting standards or under International Financial Reporting Standards, subject to

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established adjustments. Add-back adjustments of the financial result for tax purposes include the following:

• Thirty percent of the cost of goods, including non-current as sets (except for purchased right-of-use assets under lease agree ments), works and services purchased from or supplied to nonresidents registered in low-tax and non-transparent jurisdic tions, nonresidents incorporated in specific legal forms that do not pay CPT and/or are not tax residents in their country of registration or purchased from nonprofit organizations if the amount of purchase from nonprofit organizations exceeds 25 minimum salaries (approximately USD5,555). This limitation does not apply to transactions falling under transfer-pricing control (see Transfer pricing in Section E) or if the taxpayer substantiates the arm’s-length level of the expenses/income under transfer-pricing rules.

• Royalties paid to nonresidents exceeding the sum of royalty income and 4% of the taxpayer’s net sales income for the pre ceding reporting year. The limitation does not apply to transac tions falling under transfer-pricing control or if the taxpayer substantiates the arm’s-length level of the royalties under transfer-pricing rules. In some cases, royalties are added back in full.

• Adjustments under the thin capitalization rules (see Debt-toequity ratios and other restrictions on the deductibility of inter est in Section E).

• Transfer-pricing adjustments.

• Provisions and allowances accrued in financial accounting (except for salary and payroll tax provisions).

• Funds or cost of goods, works or services provided to nonprofit organizations in an amount exceeding 4% (8% for sports nonprofit organizations) of the taxpayer’s taxable profit for the preceding year.

• Non-repayable financial aid, or the cost of goods, works or services provided for free, to entities (other than registered nonprofit organizations and individuals) that are not CPT payers or are CPT exempt, or to parties related to CPT payers (if the recipients of such aid declared tax losses for the previous reporting year, provided that the donor recognized such aid as expenses when determining its pre-tax financial result).

• Penalties under civil law contracts, compensation for damages and lost profit paid to non-CPT payers (except for individuals) or to CPT payers that enjoy CPT exemption, and fines and penalties imposed by tax and other authorities.

• Impairment of fixed assets and intangible assets.

• Losses from participation in the equity of other companies.

• Value of transactions falling under transfer-pricing control that are not recognized by the tax authorities due to a lack of busi ness purpose (see Transfer pricing in Section E).

Industry-specific adjustments apply for banks and financial insti tutions.

Tax-loss carryforwards decrease the pretax financial result for CPT purposes, subject to special rules for large taxpayers. Transferability of tax losses through a reorganization is limited.

If a taxpayer’s income does not exceed UAH40 million (USD1,367,292), the taxpayer may opt not to make any adjust ments to the financial result before tax for CPT purposes.

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Depreciation. For purposes of tax depreciation, fixed assets are defined as assets that are designated for use in a taxpayer’s business activity for more than one year and that have a value exceed ing UAH20,000 (approximately USD684). The Tax Code provides for 16 groups of tangible fixed assets, 6 groups of nontangible fixed assets and 5 methods of tax depreciation. Similar to financial accounting, tax depreciation is accrued per each item.

list of depreciation methods is in line with methods stipu lated for financial accounting.

following are the methods:

Straight-line

Declining-balance

Accelerated declining-balance

Sum-of-the-years’ digits

Unit-of-production

of an asset is accrued on a monthly basis through out the useful life cycle of the asset. Depreciation is not accrued for the period of non-use of fixed assets in a business activity as a result of their conservation. The following table shows the minimum allowable term of the useful lives of assets.

Minimum term of useful life Group Assets Years

Capital expenditure on land

not related to

Buildings

Facilities

devices

Machinery and equipment

and computer equipment

Transport facilities

appliances and equipment

Animals

plants

Other fixed assets

Temporary facilities

containers

Rental objects

biological assets

of Group 1 (land plots) and Group 13 (natural resources), as well as goodwill and non-production fixed assets and intan gibles, are not subject to depreciation.

minimum term of useful life is not determined for the assets of Group 10 (library holdings) and Group 11 (tangible assets of small value).

Taxpayers should use the longer of the tax accounting or finan cial accounting depreciation terms. Accelerated depreciation is allowed in accordance with the following rules:

Starting 1 January 2017, taxpayers are allowed to depreciate under a straight-line method qualifying fixed assets of Group

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The
The
Depreciation
2
improvements,
construction 15 3
20
15 Transmission
10 4
5 Electronic
2 5
5 6 Tools,
(furniture) 4 7
6 8 Perennial
10 9
12 12
5 14 Returnable
6 15
5 16 Long-term
7 Assets
The
4

over a minimal two-year period if these assets were purchased after 1 January 2017 and put into operations before 31 December 2019. The right to use this tax incentive may be transferred upon reorganization.

• From 1 January 2020 to 31 December 2030, taxpayers may use accelerated depreciation for new machinery and equipment (Group 4) and vehicles (Group 5) within a two-year useful life and for transmission devices (Group 3) and other fixed assets (Group 9) within a five-year useful life, subject to qualifying conditions.

Relief for losses. In general, the Tax Code allows the unlimited carryforward of losses, subject to special rules for the large tax payers as outlined below. Transferability of tax losses through corporate reorganizations is subject to recently introduced spe cial rules and is limited.

Starting from 2022, the right of large taxpayers to carry forward tax losses is limited; the losses of previous periods can be carried forward until fully utilized, but only up to 50% of the unutilized amount can be deducted in a reporting period. As an exception, if the tax losses are up to 10% of taxable profit of the current period, such losses can be deducted in full.

The law does not allow tax losses to be carried back (that is, off setting the tax loss of the current year against the taxable profit of previous years to reduce tax payments). However, for taxpay ers that determine tax payable based on quarterly tax returns, the carryback of a tax loss within a year may be technically possible because tax returns are completed cumulatively.

Groups of companies. The Ukrainian tax law does not provide for the grouping of different legal entities.

D. Other significant taxes

The following table summarizes other significant taxes.

Nature of tax Rate (%)

Value-added tax (VAT)

Standard rate 20

Supply and import of certain types of agricultural products

Import and supply of pharmaceuticals, and provision of certain types of cultural and temporary accommodation services (exemptions apply)

Services for domestic transportation of passengers and luggage by air until 2024

Exports of goods and certain services

Excise tax Various Customs duties

Environmental tax Various Rent tax

Property tax Various

E. Miscellaneous matters

Foreign-exchange controls. The Ukrainian currency is the hryvnia (UAH). The official exchange rate of the hryvnia against the US dollar can be found at the National Bank of Ukraine (NBU)

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14
7
7
0
Various
Various

website (www.bank.gov.ua); the retail exchange rate may differ from the official exchange rate. Ukraine has rather strict currency control rules, but they are gradually being softened. A wide vari ety of controls are imposed with respect to the use, circulation and transfer of foreign currency within Ukraine and abroad. These controls, which affect almost all international business transactions, include the following:

• In general, transactions between Ukrainian residents and cash settlements within Ukraine may not be carried out in foreign currency.

• All statutory accounting and tax reporting, as well as tax pay ments, must be in Ukrainian currency.

• Wages and salaries paid to Ukrainian citizens must be in Ukrainian currency.

• Legal basis or obligation to perform a transaction in foreign currency that is confirmed by appropriate documents is required for the purchase of foreign currency.

• The deadline for settlements on export and import transactions is 365 days, subject to exceptions.

• There are e-limits, which are annual cap amounts for the remittance of foreign currency outside Ukraine, including the placement of own funds in foreign bank accounts and foreign investment. The limits are EUR2 million for legal entities and EUR200,000 for individuals. These e-limits are slightly modified equivalents of the previously effective individual licensing by the National Bank of Ukraine. There are exhaustive lists of transactions not falling under the limits.

• Declared (publicly announced) simplification of currency con trol over low-value transactions (up to UAH400,000) does not work because banks are required to verify that there is no artificial splitting of the transactions.

• Exporters’ transactions using the letter of credit form of pay ment are subject to simplified currency control.

• Rules for transactions related to capital movement are compli cated.

Special currency-control restrictions apply during the period of martial law in Ukraine (see Section G for more details).

Debt-to-equity ratios and other restrictions on the deductibility of interest. If a taxpayer’s debt to nonresidents exceeds its equity by at least 3.5 times, interest accrued to nonresident parties by such taxpayer may be deductible in an amount of up to 30% of the sum of its CPT base, financial expenses and tax depreciation for the reporting year. Tax losses carried forward from prior periods are not taken into account for the calculation of the CPT base in this case.

The remaining interest, annually reduced by 5%, may be carried forward indefinitely, subject to the same limitation.

Special rules apply to capitalized interest. The limitation does not apply to interest accrued in favor of international financial orga nizations (subject to certain conditions), to foreign banks or to financial companies engaged exclusively in leasing activities.

Transfer pricing. Transfer pricing (TP) rules have been effective in Ukraine since 2013. Ukrainian TP regulations are frequently changed.

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Under the current TP rules, controlled transactions include the following:

• Transactions with nonresident related parties.

• Transactions with nonresidents registered in low-tax and nontransparent jurisdictions. The government approves the list of such jurisdictions.

• Commission sales of goods and services through nonresident commissioners.

• Transactions involving goods and services between related parties through unrelated intermediaries that do not undertake significant functions, do not use significant assets and do not assume significant risks.

• Transactions with nonresidents that do not pay corporate profit tax, or are exempt from this tax and/or are not tax residents of the country where they are registered as legal entities. The gov ernment approves the list of legal forms of such nonresidents of such countries.

• Transactions between a nonresident and its PE in Ukraine.

• Transfer of functions, together with assets, risks and benefits to a related party, if the transfer results in a decrease of a taxpay er’s income and/or financial result, regardless of whether the transaction is recorded in accounting.

The abovementioned transactions are controlled if both of the following circumstances exist (for transactions between a non resident and its PE only the second circumstance needs to exist):

• The annual income of the taxpayer exceeds UAH150 million (approximately USD5,127,000).

• The amount of such annual transactions with each entity determined in line with the arm’s-length principle exceeds UAH10 million (ap proximately USD342,000).

The Tax Code provides for the following five methods for determining the arm’s-length price for controlled transactions:

• Compared uncontrolled price (the preferred method)

• Resale price

• Cost-plus

• Transactional net margin

• Profit-split

Specific profit-level indicators are assigned to each TP method.

Special rules apply to exports or imports of quoted goods.

Taxpayers that perform controlled transactions must file a TP Report (report on controlled transactions) and a notification on participation in a multinational group of companies by 1 October of the year following the reporting year. TP documentation must be submitted within 30 calendar days after the date of receipt of the request. The statute of limitations for TP purposes is cur rently seven years.

Starting from the 2021 reporting year, three-tiered TP reporting applies to qualifying cases. This reporting consists of a Master File, TP documentation (a Local File) and a country-by-country report.

Controlled foreign companies. Controlled foreign company (CFC) rules have been introduced in Ukraine. The rules relate to resi dents of Ukraine (both individuals and legal entities) that control

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companies registered outside of Ukraine, including trusts and funds. The rules introduce mandatory reporting in Ukraine and aim to tax profits of foreign companies at the level of Ukrainian controllers unless an exemption applies.

The CFC’s profit should be included in the tax base of Ukrainian controllers regardless of whether such profit is paid to these controllers. This profit can be taxable at 18%, and for dividends received by CFCs (directly or indirectly) from Ukrainian companies that are CPT payers or non-CPT payers, the rates are 5% and 9%, respectively.

There are special rules for calculation of a CFC’s taxable profit and the cases when the CFC’s profit is not included into its controller’s income. These rules depend on the effective profit tax rate, the portion of passive income in the CFC`s total income, adequate business substance at the CFC and a double tax treaty between Ukraine and the respective country. The total aggregate income of all CFCs of one controller from all sources not exceeding EUR2 million for the reporting period is exempt from taxation in Ukraine.

Controllers are required to report their control over shares in CFCs and the CFCs’ taxable profit. The first reporting period is 2022. The Tax Code allows the submission of the first report in 2024 for the first two reporting periods (2022 and 2023).

Diia City Regime. A new preferential tax regime for the IT indus try, known as the Diia City Regime, was introduced in Ukraine and became operational in February 2022.

The Diia City Regime allows companies to do the following:

• To keep paying 18% CPT under general rules

• To pay CPT under special rules, which are very similar to the rules of exit capital tax (ECT), at a 9% rate on specific transac tions and at 18% rate on controlled transactions.

A taxable object for the ECT is an exhaustive list of transactions that involve monetary or in-kind payments in favor of persons who are not residents of Diia City. Such transactions include, among others, the following:

• Distribution of dividends

• Payment of royalties in excess of 4% of net operating income for the previous year

• Payment on withdrawal of the owner of corporate rights from the participants, liquidation and repurchase of own corporate rights, in excess of the amount of investment

• Payment of interest, commissions, other rewards

• Free-of-charge provision of property, works, services or their sale without receipt of payment within 365 days and provision of financial aid that is not subject to repayment within 12 cal endar months

• Purchase of property, works, services on a prepayment basis if the delivery period exceeds 365 days from the date of payment

• Investments in objects located outside of Ukraine

• Contributions to the authorized capital, joint ventures or trust management

• Transfer of funds to own accounts in foreign banks

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• Business transactions that are recognized as controlled accord ing to Article 39 of the Tax Code if their conditions do not comply with the arm’s-length principle

• Other qualifying transactions and payments, including those in favor of nonresidents

If payments for the transactions subject to ECT are made in-kind, the tax base is determined at a value not lower than the arm’slength level.

The basic tax reporting period for ECT filing is a calendar year. Attractive personal income taxation rules apply under the Diia City Regime.

To join the Diia City Regime, a legal entity should be incorpo rated under the laws of Ukraine and meet the established eligibil ity criteria.

The Diia City Regime is supposed to be in place for 25 years.

F. Treaty withholding tax rates

Ukraine honors the double tax treaties of the former USSR, ex cept for treaties that have been superseded by new treaties con cluded directly by Ukraine or renounced by the other party to the treaty. Ukraine is not a member of the Organsiation for Economic Co-operation and Development (OECD). As a result, the Ukrainian tax authorities are not formally bound by the commentary of the OECD model convention; however, Ukrainian tax authorities and Ukrainian courts often rely on OECD commen tary. The rates in the table below reflect the treaty rates for divi dends, interest and royalties paid from Ukraine to residents of treaty jurisdictions. Exceptions or conditions may apply, depend ing on the terms of the particular treaty.

Beneficial ownership and tax residency tests, as well as addi tional eligibility conditions, must be met to apply reduced with holding tax rates under the double tax treaties. The national law details the “beneficial owner” condition and provides for the “principal purpose test” and “look through” concept.

Ukraine has ratified the Multilateral Instrument (MLI) and de posited its final positions with the OECD. On 1 December 2019, the MLI entered into force for Ukraine. The impact of the MLI on the text of Ukrainian treaties (including the date of its entry into effect for a particular treaty) should be analyzed on a caseby-case basis.

Dividends Interest Royalties % % %

Algeria 5/15 (d) 0/10 (e) 10 Armenia 5/15 (d) 0/10 (e) 0

Austria 5/15 (d) 0/5 (p) 0/5 (k)(o)

Azerbaijan 10 0/10 (e) 10

Belarus 15 10 15

Belgium 5/15 (d) 0/2/10 (h)(aa) 0/10 (k)(aa)

Brazil 10/15 (d)(ee) 0/15 (ff) 15

Bulgaria 5/15 (d) 0/10 (e) 10 Canada 5/15 (d)(pp) 0/10 (e)(nn) 0/10 (f) China Mainland (bb) 5/10 (d) 0/10 (e) 10

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Croatia

Dividends Interest Royalties % % %

5/10 (d) 0/10 (e) 10

Cyprus 5/10 (xx) 0/5 (e) 5/10 (yy)

Czech Republic

5/15 (d) 0/5 (e) 10

Denmark 5/15 (d) 0/10 (e)(oo) 0/10 (g)

Egypt 12 0/12 (e) 12

Estonia 5/15 (d) 0/10 (e) 10

Finland 0/5/15 (m) 0/5/10 (n) 0/5/10 (l)

France 0/5/15 (a) 0/2/10 (j) 0/10 (r)

Georgia 5/10 (d) 0/10 (e) 10

Germany 5/10 (d) 0/2/5 (h) 0/5 (k)

Greece 5/10 (d) 0/10 (e) 10

Hungary 5/15 (d) 0/10 (e) 5

Iceland 5/15 (d) 0/10 (jj) 10

India 10/15 (d) 0/10 (e) 10

Indonesia 10/15 (d)(qq) 0/10 (e) 10

Iran 10 0/10 (e) 10

Ireland 5/15 (d) 0/5/10 (aaa) 5/10 (yy)

Israel 5/10/15 (d)(z) 0/5/10 (dd) 10

Italy 5/15 (d) 0/10 (e) 7

Japan 15 0/10 (e) 0/10 (ww)

Jordan 10/15 (d)(ii) 0/10 (hh)(ii) 10 (ii)

Kazakhstan 5/15 (d)(pp) 0/10 (e) 10

Korea (South) 5/15 (d) 0/5 (e) 5

Kuwait 0/5 (cc) 0 10

Kyrgyzstan 5/15 (d) 0/10 (e) 10

Latvia 5/15 (d) 0/10 (e) 10

Lebanon 5/15 (d) 0/10 (e) 10

Libya 5/15 (d) 10 10 Lithuania 5/15 (d) 0/10 (e) 10 Luxembourg 5/15 (d) 0/5/10 (ccc) 5/10 (ddd)

Malaysia 5/15 (d) 0/10 (e) 8

Malta 5/15 (d) 0/10 (e) 10

Mexico 5/15 (d) 0/10 (zz) 10

Moldova 5/15 (d) 0/10 (e) 10 Mongolia 10 0/10 (rr) 10 Morocco 10 (ee) 0/10 (e) 10

Netherlands 0/5/15 (i) 0/5 (e)(rr) 5/10 (gg)

North Macedonia 5/15 (d) 0/10 (e) 10

Norway 5/15 (d) 0/10 (e)(kk) 5/10 (x)

Pakistan 10/15 (tt) 0/10 (uu) 10

Poland 5/15 (d) 0/10 (e) 10

Portugal 10/15 (q) 0/10 (e)(ll) 10

Qatar 0/5/10 (eee) 0/5/10 (fff) 5/10 (yy)

Romania 10/15 (d) 0/10 (e) 10/15 (s)

Saudi Arabia 5/15 (d) 10 10

Singapore 0/5/15 (ss) 0/10 (e) 7.5

Slovak Republic 10 10 10

Slovenia 5/15 (d) 5 5/10 (gg)

South Africa 5/15 (d) 0/10 (e)(ll) 10

Spain 15 0 0/5 (b)

Sweden 0/5/10 (d)(t) 0/10 (u) 0/10 (v)

Switzerland 0/5/15 (y) 0/5 (p) 5

Syria 10 0/10 (e) 15

Tajikistan 10 0/10 (e) 10

Thailand 10/15 (d) 0/10/15 (w) 15

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Turkey

Dividends Interest Royalties % % %

10/15 (d) 0/10 (p) 10

Turkmenistan 10 0/10 (e) 10

United Arab

Emirates 0/5/15 (y) 0/3 (e) 0/10 (k)

United Kingdom 0/5/15 (c) 0/5 (e) 5

United States 5/15 (d) 0 10

Uzbekistan 10 0/10 (e) 10

Vietnam 10 0/10 (e) 10

Yugoslavia (vv) 5/10 (d) 0/10 (e) 10

Non-treaty

jurisdictions 15 0/5/15 (bbb) 15

(a) The 0% rate applies to dividends paid to one or more companies that are the beneficial owners of these dividends and if either of the following conditions is satisfied:

• The recipient company or companies hold directly or indirectly at least 50% of the capital of the company paying the dividends, and the total amount of their investments in the paying company is not less than 5 million French francs (the tax authorities have clarified that EUR762,245 equivalent shall apply).

• The investments of the recipient companies in the company paying the dividends are guaranteed or insured by the other state, the central bank of such state or a person acting on behalf of such state.

The 5% rate applies to dividends paid to companies that own at least 20% of the capital of a Ukrainian resident payer or 10% of the capital of a French resident payer. The 15% rate applies to other dividends.

(b) The 0% rate applies to royalties paid for the use of, or the right to use, copy rights for literary, dramatic, musical or artistic works (excluding royalties with respect to cinematographic films or any means of image or sound repro duction for use in radio or television). The higher rate applies to other royal ties.

(c) The 0% rate applies if the beneficial owner of the dividends is a pension scheme. The 5% rate applies to dividends if the beneficial owner is a com pany that holds directly or indirectly at least 20% of the capital of the payer.

(d) The lower rate applies to dividends paid to companies that are the beneficial owners of such dividends and own a minimum percentage of the capital of the payer (under the treaties, this percentage ranges from 10% to 50%). The higher rate applies to other dividends. Additional conditions may apply.

(e) The 0% rate may apply to interest paid to or, in some cases, by government institutions or central banks of the contracting states. In some cases, the 0% rate also applies to the following:

• Interest paid to entities authorized by government institutions

• Interest on debt claims that are warranted, insured or directly or indirectly financed by the state or a financial institution wholly owned by the state Specific institutions are named in some treaties. The higher rate applies to other interest (additional beneficial ownership requirements may apply).

(f) The 0% rate applies to payments for the use of, or the right to use, computer software. The 10% rate applies to other royalties.

(g) The 0% rate applies to payments for the use of, or right to use, secret formu las or processes, or for information (know-how) concerning industrial, com mercial or scientific experience. The 10% rate applies to other royalties.

(h) The 0% rate applies to interest paid to the state or an agency owned or con trolled by the state and to interest paid to a resident of a contracting state with respect to a loan or other debt claim or credit granted, guaranteed or insured by public entities owned or controlled by the state (may be subject to addi tional conditions). The 2% rate applies to interest on loans from banks or financial institutions and to interest with respect to sales on credit of mer chandise or services between enterprises or sales of industrial, commercial or scientific equipment. The higher rate applies to other interest.

(i) The 0% rate applies to dividends paid to companies (other than partnerships) whose investment in the capital of the payer is guaranteed or insured by government institutions, the central bank or an agency or instrumentality (including a financial institution) owned or controlled by the government and to dividends paid to pension funds. The 5% rate applies to dividends paid to companies (other than partnerships) owning at least 20% of the payer. The 15% rate applies to other dividends.

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(j)

The 0% rate applies to interest paid to the state or an agency owned or con trolled by the state and to interest paid to a resident of a contracting state with respect to a loan or other debt claim or credit granted, guaranteed or insured by public entities owned or controlled by the state. The 2% rate applies to the following:

• Interest paid on loans granted by banks or other financial institutions of the other state

• Interest paid with respect to the sale on credit of industrial, commercial or scientific equipment, or with respect to the sale or furnishing on credit of goods or merchandise or services by an enterprise to another enterprise

The 10% rate applies to other interest.

(k) The 0% rate applies to payments for the use of, or the right to use, copyrights of scientific works, patents, trademarks, designs or models, plans, and secret formulas or processes, as well as to information concerning industrial, com mercial or scientific experience. The higher rate applies to other royalties.

(l) The 0% rate applies to royalties paid for the use of, or the right to use, com puter software, patents, designs or models, or plans. The 5% rate applies to royalties paid for the use of, or right to use, secret formulas or processes, as well as for information (know-how) concerning industrial, commercial or scientific experience. The 10% rate applies to royalties paid for the use of, or the right to use, copyrights of literary, artistic or scientific works including cinematographic films, and films or tapes for television or radio broadcast ing, or trademarks.

(m) The 0% rate applies to dividends paid by a company resident in Ukraine to a company that is resident in Finland and that is the beneficial owner of the dividends if either of the following circumstances exists:

• The Finnish Guarantee Board has issued an investment guarantee for divi dends paid or for the capital invested on which the dividends are paid.

• The recipient of the dividends has made an investment of at least USD1 mil lion in the capital of the payer and holds at least 50% of the equity capital of the company paying the dividends.

The 0% rate is allowed with respect to dividends paid for any tax year within the period for which the abovementioned guarantee is in force or, if no such guarantee is made, with respect to dividends paid for the first three years following the year in which the investment is made. The 5% rate applies to dividends paid to companies owning at least 20% of the capital of the payer.

The 15% rate applies to other dividends.

(n) The 0% rate applies if the interest is paid to the State of Finland, or a local authority or a statutory body thereof, the Bank of Finland, the Finnish Fund for Industrial Co-operation Ltd (FINNFUND) or the Finnish Export Credit Ltd or any similar institution. The 0% rate also applies to interest paid to a resident of Finland on a loan guaranteed by any of the bodies mentioned in the preceding sentence or by the Finnish Guarantee Board and paid to a resi dent of Finland. The 5% rate applies to interest related to commercial credit (except when the sale or indebtedness is between related persons). The 10% rate applies to other interest.

(o) The protocol amending the tax treaty increases tax rates for royalties starting from 1 January 2023. A 5% rate will apply to royalties paid for the use of, or right to use, scientific works, patents, trademarks, designs or models, plans, secret formulas or processes, or for information concerning industrial, com mercial or scientific experience. A 10% rate will apply to royalties paid for the use of, or the right to use, copyrights of literary or artistic works, includ ing cinematographic films, and tapes for television or radio broadcasting.

(p) The 0% rate applies to the following types of interest:

• Interest paid to a beneficial owner that is the state, a political subdivision or local authority or the central bank

• Interest paid by the state in which the interest arises or by a political subdi vision or local authority

• Interest paid with respect to a loan, debt claim or credit that is owed to, made, provided, guaranteed or insured by the state or a political subdivision or local authority (or by an export financing agency)

The higher rate applies to other interest.

(q) The 10% rate applies to dividends paid to the beneficial owner if, for an uninterrupted period of two years before the payment of the dividend, the beneficial owner owned directly at least 25% of the capital stock of the com pany paying the dividends. The higher rate applies to other dividends.

(r) The 0% rate applies to payments for the use of, or the right to use, software, patents, trademarks, designs or models, plans, or secret formulas or pro cesses, or for information concerning industrial, commercial or scientific experience. The 10% rate applies to other royalties.

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(s)

The 10% rate applies to royalties paid for the use of, or the right to use, pat ents, trademarks, designs or models, secret formulas or processes, as well as for information concerning industrial, commercial or scientific experience. The 15% rate applies to other royalties.

(t) The 0% rate applies if the beneficial owner of the dividends is a company (other than a partnership) that holds directly at least 25% of the voting power of the payer of the dividends and if at least 50% of the voting power of the company that is the beneficial owner of the dividends is held by residents of the beneficial owner’s contracting state.

(u) The 0% rate applies to the following:

• Interest paid on loans provided, guaranteed or insured by a government of a state where the beneficial owner of the interest is located, or interest on loans made, guaranteed or insured on behalf of such government by an authority thereof that is so entrusted

• Interest with respect to indebtedness arising on sales on credit by enter prises of merchandise or industrial, commercial or scientific equipment to an enterprise of another contracting state, unless the sale or indebtedness is between related persons

The 10% rate applies to other interest payments.

(v) The 0% rate applies to royalties paid for patents concerning industrial and manufacturing know-how or processes, agriculture, pharmaceuticals, com puters, software, building constructions, secret formulas or processes, as well as for information concerning industrial, commercial or scientific experi ence. The 10% rate applies to other royalties.

(w) The 0% rate applies to interest derived by the government, a political subdi vision or a local authority, central bank of a contracting state or other finan cial institution established and owned by the government to promote trade and investment, as well as to interest paid to residents of a contracting state with respect to debt-claims guaranteed or insured by the government, a local authority thereof, the central bank or other financial institution established and owned by the government to promote trade and investment. The 10% rate applies to interest paid on loans granted by banks or other financial institutions, including investment banks, savings banks and insurance com panies. The 15% rate applies to other interest payments.

(x) The 5% rate applies to royalties paid for the use of, or the right to use, pat ents, plans, secret formulas or processes, as well as for information (knowhow) concerning industrial, commercial or scientific experience. The 10% rate applies to other royalties.

(y) The 0% rate applies to dividends paid to the government, a political subdivi sion or local authority, central bank or other state financial institution. The 5% rate applies to dividends paid to companies owning at least 10% of the capital of the payer. The 15% rate applies to other dividends.

(z) Notwithstanding the provisions allowing the 5% reduced rate (see footnote [d]), the 10% rate applies if the beneficial owner of the dividends is a com pany that holds directly at least 10% of the capital of the company paying the dividends and if the dividend payer is a resident of Israel and the divi dends are paid out of profits that are subject to tax in Israel at a rate that is lower than the normal rate of Israeli company tax.

(aa) A discrepancy exists between the Ukrainian and English texts of the Belgium treaty with respect to the withholding tax rates for interest and royalties. In the Ukrainian version, the highest treaty rate is 5%, while in the English version, it is 10%. The English version prevails in accordance with Paragraph (e) of the protocol to the treaty.

(bb) The treaty does not apply to the Hong Kong Special Administrative Region (SAR).

(cc) The 0% rate applies to dividends paid to the government, a political subdivi sion or local authority, the central bank or other state financial institution. The 5% rate applies to all other dividends.

(dd) The 0% rate applies to interest paid on loans granted by the government of a contracting state, including its political subdivisions and local authorities, the central bank or financial instrumentalities of that government. The 5% rate applies to interest paid on loans granted by banks. The 10% rate applies to all other interest payments.

(ee) If a resident of a contracting state has a PE in the other state, such PE may be subject to a withholding tax under the law of that other state. However, this tax may not exceed 10% of the amount of the profits of that PE after payment of the corporate tax on the profits.

(ff) Interest arising in a contracting state and paid to the government of the other contracting state, political subdivisions thereof or agencies (including finan cial institutions) wholly owned by that government or a political subdivision is exempt from tax in the state where the income arises, unless the rule mentioned in the following sentence applies. Interest on securities, bonds or

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debentures issued by the government of a contracting state, political subdivi sions thereof or agencies (including financial institutions) wholly owned by that government or political subdivision thereof is taxable only in that state.

(gg) The 5% rate applies to royalties paid for the use of, or right to use, scien tific works, patents, trademarks, designs or models, plans, secret formulas or processes, or, in some cases, industrial, commercial or scientific equip ment, or for information concerning industrial, commercial or scientific experience. The 10% rate applies to royalties paid for the use of, or the right to use, copyrights of literary or artistic works, including cinematographic films, and tapes for television or radio broadcasting.

(hh) Interest derived by the government of the contracting state including local authorities thereof, a political subdivision, the central bank or any financial institution controlled by such government, the capital of which is wholly owned by the government of the contracting state, is exempt from tax.

(ii) The treaty rates do not apply to residents of a contracting state who perform their activity outside of this state if the income and profits of such persons are exempt from tax or are taxed at a substantially lower rate in such state.

(jj) The 0% rate applies if interest is received and actually held by the govern ment or a political subdivision. Interest paid to and held by a resident of one contracting state is exempt from tax in the other contracting state if it is paid with respect to a loan made, guaranteed or insured or with respect to any other debt claim or credit, if the loan, debt claim or credit is guaranteed or insured on behalf of the first-mentioned state or by an authorized organ.

(kk) The 0% rate also applies if the interest is paid by a purchaser to a seller with respect to commercial credit resulting from deferred payments for goods, merchandise, equipment or services, unless the sale or indebtedness is between associated persons.

(ll) The 0% rate also applies to interest paid to an institution (including a financial institution) with respect to a loan made under an agreement between the governments of the contracting states.

(mm) The reduced rates apply if the beneficial owner of the dividends is subject to tax with respect to such dividends.

(nn) The 0% rate also applies to interest arising in a contracting state and paid to a resident of the other contracting state that was established and operated exclusively to administer or provide benefits under one or more pension, retirement or other employee benefits plans if the following conditions are satisfied:

• The recipient is the beneficial owner of the interest and is generally exempt from tax in the other state.

• The interest is not derived from the carrying on of a trade or a business or from a related person.

(oo) The 0% rate also applies to interest paid with respect to indebtedness incurred in connection with the sale on credit of industrial, commercial or scientific equipment by an enterprise that is resident of one contracting state to an enterprise resident in the other contracting state, unless the sale or indebtedness is between associated enterprises.

(pp) Tax imposed on the earnings of a company attributable to a PE in a con tracting state in addition to the tax that would be chargeable on the earnings of a company that is a national of that state may not exceed 5% of the amount of such earnings.

(qq) If a resident of a contracting state has a PE in the other state, such PE may be subject to a withholding tax under the law of that other state. However, this tax may not exceed 10% of the amount of the profits of that PE after payment of the corporate tax on the profits. This measure does not affect provisions contained in production-sharing contracts and contracts of work (or any other similar contracts) relating to the oil and gas sector or other mining sector entered into by the government of Indonesia, its instrumen talities, its relevant state oil and gas company or any other entities of the government of Indonesia, with a person that is a resident of the other con tracting state.

(rr) The 0% rate applies to the interest paid with respect to bonds, debentures or similar obligations of the government, political subdivisions, local authori ties or the central bank.

(ss) The 0% rate applies to dividends if the beneficial owner of the dividends is the government, the central bank, or other government institutions or statu tory bodies. The 5% rate applies to dividends if the beneficial owner is a company (other than a partnership) that holds directly at least 20% of the capital of the payer. The 15% rate applies to other dividends.

(tt) The 10% rate applies to dividends paid to the beneficial owner of the divi dends if the beneficial owner owns directly at least 25% of the capital stock of the company paying the dividends. The 15% rate applies to other divi dends.

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(uu)

The 0% rate applies to interest received and belonging to the government, political subdivisions, local authorities or the central bank.

(vv) The double tax treaty with Yugoslavia applies to Serbia and Montenegro.

(ww) The 0% rate applies to royalties paid for the use of, or the right to use, copyrights of literary, artistic or scientific works, including cinemato graphic films and films or tapes for radio or television broadcasting. The 10% rate applies to the royalties for the use of, or the right to use, patents, trademarks, designs or models, plans, secret formulas or processes, or industrial, commercial or scientific equipment, or for information concern ing industrial, commercial or scientific experience.

(xx) The 5% rate applies to dividends paid to the beneficial owner of the divi dends if such owner holds at least 20% of the capital of the company paying the dividends and has invested in the acquisition of the shares or other rights of the company the equivalent of at least EUR100,000. The 10% rate applies in all other cases.

(yy) The 5% rate applies to royalties with respect to copyrights of scientific works, patents, trademarks, secret formulas, processes or information con cerning industrial, commercial or scientific experience. The 10% rate ap plies in other cases.

(zz) The 0% rate applies to the following types of interest:

• Interest paid to or by the state, political subdivision or central bank

• Interest arising and paid with respect to a loan granted for a term over three years that is guaranteed or insured or to a credit granted for a term over three years that is guaranteed or insured by the authorized state institutions

The 10% rate applies in other cases. The procedure for application of these restrictions will be set by the competent authorities of Mexico and Ukraine.

(aaa) The 0% rate applies to interest if any of the following circumstances exist:

• The beneficial owner of the interest is the government or an agency authorized by the government.

• The interest is paid with respect to loans made, guaranteed or issued by or on behalf of the government or an agency authorized by the govern ment.

• The interest is paid with respect to debt claims that are warranted, insured, or directly or indirectly financed by the government or an agency authorized by the government.

The 5% rate applies to interest paid in connection with the sale on credit of industrial, commercial or scientific equipment, or in connection with loans granted by banks. The 10% rate applies in all other cases if the recipient of the interest is resident in either treaty state and is the beneficial owner of the interest.

(bbb) See footnotes (b) and (c) in Section A.

(ccc) The 0% rate applies to interest paid with respect to a loan made, guaranteed or insured, or with respect to any other debt claim or credit guaranteed or insured, on behalf of the state by its authorized body. The 5% rate applies to interest paid on loans granted by banks and other financial institutions (including investment banks and savings banks). The 10% rate applies to all other interest payments.

(ddd) The 5% rate applies to royalties paid for the use of, or the right to use, patents, trademarks, designs or models, plans, secret formulas or processes, as well as for information (know-how) concerning industrial, commercial or scientific experience. The 10% rate applies to royalties paid for the use of, or the right to use, copyrights of literary, artistic or scientific works including cinematographic films, and films or tapes for television or radio broadcasting.

(eee) The 0% rate applies to dividends paid to the government, a political subdi vision or local authority, the central bank or other state financial institution. The 5% rate applies to dividends if the beneficial owner is a company (other than a partnership) that holds directly at least 10% of the capital of the payer. The 10% rate applies to other dividends.

(fff) The 0% rate applies to interest paid to the government, a political subdivi sion, local authority, a statutory body or the central bank. The 5% rate applies if the interest is paid in connection with the sale on credit of indus trial, commercial or scientific equipment or on any loan of whatever kind granted by a bank. The 10% rate applies to other interest.

Ukraine has signed a new double tax treaty with Spain. The treaty is pending ratification.

Ukraine has signed a protocol amending the double tax treaty with Qatar, which is pending ratification.

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Ukraine has ratified a double tax treaty with Cuba, a protocol amending the double tax treaty with Denmark and a protocol amending the double tax treaty with United Arab Emirates, but these instruments are not yet effective.

The Minister of Finance has been authorized to sign a tax treaty with Oman and a tax treaty with Sri Lanka.

Ukraine is negotiating double tax treaties with Japan, Kenya and New Zealand and an amendment to its double tax treaty with Belgium.

Effective from 8 June 2022, the agreement between the Government of Ukraine and the Government of the Russian Federation on avoidance of double taxation of income and property and prevention of tax evasion is denounced.

G. Special rules for the period of martial law in Ukraine

Martial law was introduced in Ukraine on 24 February 2022 by the Decree of the President of Ukraine No. 64/2022 “On Martial Law in Ukraine”. A package of laws amending Ukrainian tax regulations for the period of martial law has been enacted, and more changes continue to be adopted. This package establishes special tax rules effective during the period of martial law and includes, among others, the changes described below.

Special CPT rules. Key CPT changes include the following:

• Starting 1 April 2022, a special 2% single tax rate based on income is available for Ukrainian companies (instead of 18% CPT and 20% VAT). Taxable income shall be calculated on a cash basis, considering special rules. If the legal entity is a VAT payer, during the application of the single tax regime, its regis tration as a VAT payer is suspended. As a result, such legal entity is exempt from the obligation to charge and pay VAT on supplies of goods and services, except for the importation of goods into Ukraine, and has no right to credit input VAT. After return to the general tax rules, VAT registration will be renewed and legal entities will need to self-charge notional VAT liabili ties on goods, services and non-current assets that were pur chased with VAT before the transition to the single tax regime but were used or sold without VAT during the use of the simpli fied taxation regime.

• Donations in favor of the Armed Forces of Ukraine and qualify ing military establishments (the exhaustive list of such military establishments are set out by the law) are allowed for CPT deduction in full.

In addition, several tax relief rules referring to tax administration and compliance are introduced.

Tax rules for the period of martial law may be further amended or supplemented. Monitoring legislative developments is strong ly recommended.

Special foreign-exchange restrictions. Despite the introduction of martial law on the territory of Ukraine, the Ukrainian banking system continues to work, but there is no proper currency market due to restrictions established by the National Bank of Ukraine. These restrictions include the following:

• Cross-border transactions are substantially limited.

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• Payments in foreign currency by residents for the purchase of services are suspended except for certain specifically permitted transactions as per the approved list (within the period of 24 February 2022 to 9 July 2022, payments in foreign currency for goods were allowed only for critical import goods on the approved list).

• The statutory deadline for cross-border settlements is reduced for transactions made starting 5 April 2022.

• Settlements in Russian rubles and Belarussian rubles, as well as settlements of Russian and Belarusian residents, are prohibited.

• The official exchange rate of UAH to USD is fixed at the rate valid as of 24 February 2022 (UAH29.2549 for USD1). Business entities must convert their foreign currency proceeds into UAH at this fixed rate while the retail rate is notably dif ferent.

• Restrictions on cash withdrawals by individuals are introduced (tougher restrictions for withdrawals abroad and lighter restric tions for withdrawals on the territory of Ukraine).

Currency-control rules for the period of martial law may be fur ther amended or supplemented. Monitoring legislative developments is strongly recommended.

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