Ukraine Will Start to Tax Dividends Paid to Non-Residents in AML Move

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Ukraine’s legislature has approved Law of Ukraine No 1210; implementing a bundle of anti-offshoring laws aimed at preventing profit-shifting by international corporations and Ukrainian Holding companies. From July 1st 2020, companies will be taxed if the company is majority owned by a foreign legal entity using the following source of income:

Disposals of a domestic company’s shares.
Interest on business assets.
Profits derived from corporate or similar rights.
Additionally, from January 1st 2021, a range of payment types made by a legal entity in Ukraine to non-residents will be taxable as dividends. Definitions of permanent establishment and controlled foreign companies have also been announced.