ABSTRACT
The article provides for concise yet instructive overview of
the Ukraine s participation in the BEPS agenda. It examines the
fulfillment of Ukraine s commitment to implement the anti-BEPS
initiatives, as well as observes the way in which it was made. The
article also provides for brief comments on potential effect the
introduced changes might have on the existing tax practices
exercised by Ukrainian enterprises and international businesses
using Ukrainian jurisdiction.
INTRODUCTION
In 2013, Organization for Economic Cooperation and Development,
jointly with G20 initiated Base Erosion and Profit Shifting (BEPS)
Project aimed at tackling tax planning strategies that exploit
loopholes and mismatches in international tax legislation to shift
INTM100000 - International Manual - HMRC internal manual gov.uk - get the latest breaking news, showbiz & celebrity photos, sport news & rumours, viral videos and top stories from gov.uk Daily Mail and Mail on Sunday newspapers.
Euromoney Institutional Investor plc v HMRC, the FTT
held that the share for share exchange treatment in section 135 TCGA 1992 applied despite the presence of a tax avoidance purpose.
Euromoney sold its shares in a subsidiary company to a third party buyer. The consideration was originally intended to be satisfied by ordinary shares and cash. However, upon the advice of the company’s tax director, the cash portion of the consideration was substituted for preference shares so as to allow the transaction to benefit from share for share exchange treatment under section 135 TCGA 1992 (and thus prevent an immediate tax charge). Following a 12 month ownership period, the preference shares could then be redeemed with the benefit of the substantial shareholding exemption (SSE) applying to the redemption given the holding of the ordinary shares so that the disposal of the preference shares would be exempt from corporation tax on chargeable gains.
A closer look at TP documentation in Cyprus internationaltaxreview.com - get the latest breaking news, showbiz & celebrity photos, sport news & rumours, viral videos and top stories from internationaltaxreview.com Daily Mail and Mail on Sunday newspapers.
Monday, 12 April 2021, 13:16
MPs ratify protocol on avoidance of double taxation between Ukraine and Austria
16.12.2020 17:30
Ukrinform
The Verkhovna Rada, Ukraine s parliament, has ratified the Protocol on Amendments to the Convention between the Government of Ukraine and the Government of Austria on Avoidance of Double Taxation and Prevention of Tax Evasion with respect to Taxes on Income and Capital Gains, the Ukrainian Finance Ministry s press service has reported.
The Protocol amends the Convention in order to bring its provisions into line with the OECD Model Tax Convention on Income and on Capital and the latest OECD standards.
The document provides, in particular, for an increase in the general tax rate on dividends from 10% to 15% and interest from 2% to 5%. Royalty tax rates were also increased: from 0% to 5% for the use of any copyright in scientific works, patents, etc., and from 5% to 10% for the use of copyright in literary works or works of art.