Ukraine changed definition of "low-tax jurisdiction" for transfer pricing purposes

Ukraine changed definition of "low-tax jurisdiction" for transfer pricing purposes

On 12 November 2013 Law from 24.10.2013 г. № 657-VІІ “On Changes to the Tax Code of Ukraine in respect of recording and registering taxpayers and improving certain provisions” that changed the definition of a "low tax jurisdiction" for transfer pricing purposes (identifying controlled transactions), has been published in the official gazette «Golos Ukrainy», the issue № 212. The list of the low tax jurisdictions will be set by the Cabinet of Ministers of Ukraine.

Now a "low tax jurisdiction" will be a jurisdiction that has a corporate tax rate that is five (5) percentage points below the Ukrainian tax rate, i.e. 14% and less in 2013, and in 2014 - 11% and less (under XX.4.10. of the Ukraine’s Tax Code it is provided that starting from 1 January 2014 the corporate tax rate to be reduce from 19% to 16%).

The main intrigue now is whether Ukraine takes into account the recommendation of the International Monetary Fund to postpone the scheduled corporate tax rate reduction.


© 1997—2014 DS Express, Inc

84, Spyrou Kyprianou, 

2nd floor, Limassol 4004


tel +357 25 731-042


11 Solzhenitsyna Street

Moscow 109004 Russia

tel +7 495 956-1727

fax +7 495 234-0735

15 Kreshchatik Street, office 149

Kyiv 01001 Ukraine

tel +38 044 237-2222

fax +38 044 278-6714


52 Angliyskaya Emb., office 28

St.Petersburg 190000 Russia

tel +7 812 570-1564

fax +7 812 325-723

More contact details and office maps can be found in the section Contacts

© 2015 DS Express Ltd  All rights reserved