Hot Issue (#12 December 2018)

Taxation of Permanent Establishment Financing in Ukraine: The Never-Ending Story

by Vitalii Trachuk , Khrystyna Knygynytska

Not many foreign companies today would be brave enough to choose conducting business in Ukraine through a registered representative office for obvious reasons of legal uncertainty and scrutiny of the tax office.

Nevertheless, when the Ukrainian tax system was being formed, registration of a representative office was a rather favored option by foreign companies. For tax purposes, such representative offices would normally be registered as permanent establishments (PEs), even if they were to serve “non-commercial” purposes (i.e., to conduct merely preparatory and auxiliary activity for its head office)...

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