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All non-residents/permanent establishments are required to [re]register with the tax authorities

authors: Alexander Minin, Yaroslava Ivasiuk

12 February, 2021 Exclusive

Last year a number of changes were introduced to the Tax Code of Ukraine (the “Tax Code”). In this material we analyse some aspects of the changes in the definition of income tax payers regarding non-residents and their permanent establishments in Ukraine.


The Law "On amendments to the Tax Code of Ukraine regarding improvement of tax administration, elimination of technical and logical inconsistencies in tax legislation" (the “Law 466”) amended, in particular, para. 133.2 of Art. 133 of the Tax Code, which defines the list of non-resident income tax payers:

"133.2. Non-resident taxpayers are:

133.2.2. non-residents conducting business activity at the territory of Ukraine through the permanent establishment and/or receiving income from Ukrainian sources as well as other non-residents obliged to pay the tax in accordance with this Section".

While in the preceding version of this subparagraph only "permanent establishments of non-residents that receive their income from the Ukrainian sources…" were mentioned.

Thus, previously a non-resident's permanent establishment was treated as a separate category for the purposes of the income tax. Now, non-resident entities conducting their business in Ukraine through permanent establishments and receiving income form Ukrainian sources are considered as relevant taxpayers.

What are the consequences to arise in this case? And what actions and decisions can be required on a practical level now? ...


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