Ukraine: Technical Assistance Report-Distributed Profit Tax; Voluntary Disclosure of Assets; and BEPs Implementation
IMF Staff Country Reports, November 25, 2019
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- Ukraine: Technical Assistance Report-Distributed Profit Tax; Voluntary Disclosure of Assets; and BEPs Implementation
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Bibliographic details
- Published: November 25, 2019
- Series: IMF Staff Country Reports
- DOI: https://doi.org/10.5089/9781513521046.002
Focus and scope
- The report focuses on Ukraine’s distributed profit tax, voluntary disclosure of assets, and Base Erosion and Profit Shifting Work Program implementation.
- Recommendations emphasize simplifying rules, improving definitions of basic concepts, eliminating potential loopholes, and adhering more closely to international standards in some cases.
Key substantive findings and recommendations
- Controlled Foreign Corporation (CFC) rules
- Recommendation: CFC rules should apply to the “first onshore” person rather than tracing them back to the ultimate beneficial owner in Ukraine (recommended for simplification).
- Interest deduction limitation
- Recommendation: eliminate the carry-forward currently permitted.
- Recommendation: limit deductions to net interest expense.
- Recommendation: exempt the financial sector from this limitation.
- Definitions and concepts
- Recommendation: improve several key definitions to reduce ambiguity and potential loopholes.
- Accelerated depreciation for investment promotion
- Recommendation: if there is an urgent need to promote private investments, apply the accelerated depreciation tool for plant and machinery and structures housing them for say another five years.
Policy implications and orientation
- The overall orientation of recommendations is toward simplification of tax rules and closer alignment with international standards.
- Emphasis on removing unnecessary complexity that would otherwise require tracing ownership back to ultimate beneficial owners.
- Targeted exemptions (for example, financial sector exemption from interest limitation) are proposed to avoid undue burden on specific sectors.
Publication and document identifiers
- Publication title: Ukraine: Technical Assistance Report-Distributed Profit Tax; Voluntary Disclosure of Assets; and BEPs Implementation
- Publication date: November 25, 2019
- Pages: 79
- Volume: 2019
- Issue: 352
- Series: Country Report No. 2019/352
- DOI: https://doi.org/10.5089/9781513521046.002
- Stock No: 1UKREA2019005
- ISBN: 9781513521046
- ISSN: 1934-7685
International Monetary Fund. Fiscal Affairs Dept. "Ukraine: Technical Assistance Report-Distributed Profit Tax; Voluntary Disclosure of Assets; and BEPs Implementation", IMF Staff Country Reports 2019, 352 (2019).
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- 1ukrea2019005