+ Word must be in search result. - Words must not be in search result. * Word start/end on characters before/after symbol. ""Words in quotes will be searched as phrase.

 

Is it legitimate to apply the benefits under the Treaties for Elimination of Double Taxation to the payments from Ukraine made by entities exempt from income tax?

23 May, 2017 Exclusive

The struggle against erosion of tax base is growing not only in the world, but also in Ukraine. One of the directions of this struggle is the revision of the grounds for application of the benefits under the Treaties for Elimination of Double Taxation. Today, however, such efforts are focused mainly on the analysis of the status of the recipients of payments from the territory of Ukraine, in particular, on the question, whether the recipients of payments are considered to be tax residents for the purpose of conventions and/or beneficiary owners of such payments. However, as a condition for application of the benefits under the conventions the tax residency of the recipient is equally important as that of the payer.

This review analyses whether we can apply the exemption or reduction of the tax rates on dividends, interest, and royalties in case of payments to non-residents from the territory of Ukraine executed by entities, which are exempt from corporate income tax, such as single tax enterprises (including agriculture manufacturers – single tax payers of the fourth group), or collective investment institutions.

  ...

 

Full text is open only for the subscribers.

Views 1131

SIMILAR POSTS

Double Tax Treaty with Austria: what changes and when 08 July, 2021    368

Amendments to the Convention between Ukraine and the Kingdom of the Netherlands on the Avoidance of Double Taxation from 2022 25 June, 2021    470

Interest payment to Cyprus: pitfalls of applying the Convention 03 December, 2019    5336

Verkhovna Rada of Ukraine has ratified several Protocols on Avoidance of Double Taxation: amendments 31 October, 2019    865

Internal accounting of tax authorities vs primary documents of the taxpayer: the position of the Supreme Court 28 May, 2019    1758

Whether income upon credit’s receipt or upon some other long-term debt’s appearance is recognized for the taxation purpose? 28 December, 2018    802

Exit Capital Tax 2019 — leave them, kids, alone 19 November, 2018    1273

Leave us alone. How the Exit Capital Tax will change business behavior 16 November, 2018    1688

Corporate Profit Tax: an obstacle to GDP growth 14 November, 2018    1671

Why the Exit Capital Tax should be implemented, rather than just keep struggling with corruption and fostering/upgrading qualification of tax authorities as yet 07 November, 2018    2189

They looked as if they had complete confidence in their conclusions but then just changed their minds:
the State Fiscal Service of Ukraine insists that there is no need to make quarterly 30 % adjustments in transactions with companies registered in «low tax» jurisdictions and companies with legal forms included into the special list adopted by CMU
26 October, 2018    1399

#8557 #ECT and Net Assets 13 September, 2018    2195

Comment