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

International Monetary Fund

No 2019/352, IMF Staff Country Reports from International Monetary Fund

Abstract: 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.

Keywords: ISCR; CR; passive income; parent company; tax amnesty; accelerated depreciation; capital gain; CFC income; tax authority; double taxation; transfer pricing; tax burden; CFC rule; income tax; tax treaty; tax code; Personal income; Double taxation; Controlled foreign corporation rules; Foreign assets; Tax law; Global; Africa (search for similar items in EconPapers)
Pages: 79
Date: 2019-11-25
New Economics Papers: this item is included in nep-acc and nep-cis
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