IFA Ukraine was pleased to hold IFA Ukraine Technical Meeting, designed to enhance professional discussions on international tax matters within the framework of our organization.
The following topics were discussed:
1. Review of the Draft Letter to Mr. Yuriy Gladun, STA, regarding i) application of DTT with Netherlands, ii) issues related to taxation of Ukrainian source income, iii) beneficial ownership definition; iv) validity of gross-up provisions in cross-border financing agreements.
2. Issues related to tax treatment of foreign exchange gain and losses, arising in international transactions; classification of foreign exchange gain and losses under provision of double tax treaties.
3. Ruling of Customs State Service of Ukraine on sale of shares in companies with foreign investments, and its effect on import duty exemption for in-kind contributions to capital.
4. Taxation of financing, received by PE from the head office.
As a result, meeting attendees aggreed to address State authorities on a number of discussed issues.