IMF Staff Country Reports

Ukraine: Technical Assistance Report-Distributed Profit Tax; Voluntary Disclosure of Assets; and BEPs Implementation

November 25, 2019

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Ukraine: Technical Assistance Report-Distributed Profit Tax; Voluntary Disclosure of Assets; and BEPs Implementation, (USA: International Monetary Fund, 2019) accessed September 18, 2024

Summary

This Technical Assistance report focuses on Ukraine’s distributed profit tax, voluntary disclosure of assets, and Base Erosion and Profit Shifting Work Program implementation. The recommendations largely favor simplifying rules, improving the definition of basic concepts, eliminating potential loopholes, and adhering more closely to international standards in some cases. Thus, for the sake of simplification, the report recommends that Controlled Foreign Corporation rules should apply to the ‘first onshore’ person rather than having to trace them back to the ultimate beneficial owner in Ukraine. Also, it recommends that the proposed interest deduction limitation should eliminate the carry-forward currently permitted, limit deductions to net interest expense and exempt the financial sector from this limitation. Some key definitions can be improved too. The report suggests that if there is an urgent need to promote private investments, the accelerated depreciation tool should be applied for plant and machinery and structures housing them for say another five years.

Subject: Controlled foreign corporation rules, Double taxation, External position, Foreign assets, National accounts, Personal income, Tax law, Tax policy, Taxes

Keywords: Accelerated depreciation, Africa, Capital gain, CFC income, CFC rule, Controlled foreign corporation rules, CR, Double taxation, Double taxation, Foreign assets, Global, Income tax, ISCR, Parent company, Passive income, Personal income, Tax amnesty, Tax authority, Tax burden, Tax code, Tax law, Tax treaty, Transfer pricing

Publication Details

  • Pages:

    79

  • Volume:

    ---

  • DOI:

    ---

  • Issue:

    ---

  • Series:

    Country Report No. 2019/352

  • Stock No:

    1UKREA2019005

  • ISBN:

    9781513521046

  • ISSN:

    1934-7685

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