First steps for new customs authorisation

Law No 141-IX of 2 October 2019 introduced comprehensive changes to the Customs Code of Ukraine, aimed at making the rules on AEO operational and bringing them into line with similar European regulations. According to these rules, there are two types of customs authorisation:

• AEO-S: on the entitlement to special simplifications
• AEO-B: on the confirmation of security and reliability

Companies may choose one of the customs authorisation types, or apply for both. They are different in terms of the available advantages and criteria which should be met as conditions for obtaining the status.

Advantages and special simplifications

The advantages of both AEO-S and AEO-B status are as follows:

• Customs formalities in the first order;
• Lower level of risk in the Automated System of Customs Control for defining the list of customs formalities;
• Use of designated traffic lane at customs posts;
• Use of national AEO logo

The list of special simplifications, however, is wider in the case of obtained AEO-S status. While the AEO-S status implies a general financial guarantee, the right to use customs seals of a special type, a simplified declaration procedure and customs clearance procedures on-site, special simplification for AEO-B only includes the right to use customs seals of a special type.

The customs clearance procedure is the most useful amongst the special simplifications as it offers material time and cost savings due to the peculiarities of customs clearance practices in Ukraine.

Essentially, similar cost savings are currently achieved by applying the customs clearance procedure under the “EA” preliminary import customs declaration. However, from 7 November 2022, this procedure will no longer be available. Hence, if no changes are implemented into the Customs Code by this date, cost savings will be available only for companies with AEO-S authorisation.

Conditions of the new customs authorisation in Ukraine

According to the Ukrainian Customs Code, the AEO status is available for any resident enterprise that performs any role in the international supply chain (producer, exporter, importer, customs representative, forwarder, warehouse keeper).

At the same time, during the transition period (first three years), the customs service will consider applications for AEO-S only from companies that are simultaneously producers and exporters (importers). There are no such limitations for AEO-B authorisation.

To be eligible for obtaining the status, companies should comply with the criteria established by the Customs Code. The criteria differ slightly depending on the type of AEO, and are as follows:

This customs authorisation may offer material advantages and simplify customs clearance in Ukraine. Hence, we encourage businesses to consider this opportunity.In July 2020, the Cabinet of Ministers of Ukraine adopted the procedural regulations which gave the “green light” to launch the new customs authorisation. In March 2021, the Ministry of Finance reported on the first AEO status obtained by JT International Ukraine. Thus the procedure for obtaining AEO status is now fully operational.

If you would like to know more about the new customs authorisation types and need help to access the simplified customs procedures in Ukraine, please contact the experts of WTS Tax Legal Consulting, LLC, the exclusive representative of WTS Global in Ukraine.

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Definition of business purpose according to Law 466-IX

Ukrainian Tax Code has contained the definition of the reasonable economic purpose (business aim) of transactions since its adoption back in 2010. Yet, this definition was unclear, and the ways of its practical application were limited.

Law 466-IX, which came into force in May 2020, introduced comprehensive changes into the Tax Code of Ukraine, including implementation of BEPS three-tier reporting standard. Alongside these important changes, the rules on business purpose were amended as well.

According to the definition, “reasonable economic purpose (business aim)” is the purpose that may occur on condition that a taxpayer aims at reaching certain economic goal in the result of business activity. Law 466-IX supplemented this definition with the explanation on what such economic goal may be and what transactions should be deemed as not having “reasonable economic purpose”. An economic goal (effect) particularly but without limitation should mean increase (saving) of the taxpayer’s assets and/or of their value in future.

At the same time, for taxation purposes, a transaction with non-resident is considered not have a reasonable economic purpose if:

• its principal aim or one of them is non-payment (underpayment) of taxes and/or decrease of the profit tax base;
• in comparable circumstances an entity would not be prepared to sell (purchase) such goods, works or services, intangible assets, or other items to (from) an unrelated party.

The Law 466-IX also specified how the business purpose test may impact the tax position.

Thus, new adjustment of the profit tax base was introduced into Article 140.5 of the Ukrainian Tax Code. According to it, the taxpayer shall increase the amount of taxable profit by the amount of expenses, incurred in transactions with non-residents if such transactions lack business purpose. The burden of proof in this case is levied on the tax office.

In other words, in the version of Law 466-IX, the test was applicable to any purchases from non-residents. And if the tax office challenges the reasonable economic purpose, such expenses may be disregarded when calculating the profit tax base.

Amendments by Law 1117-IX

However, such rules were amended by the Law 1117-IX, which came in force on 1 January 2021. According to these amendments, the test is applicable only to transactions with non-residents subject to transfer pricing (TP) control, transactions on payment of royalty, and transactions with non-residents that fall under the list of “low tax” states (territories) or the list of organizational forms of non-residents (covering fiscally transparent entities), adopted by the Cabinet of Ministers of Ukraine.

The Law also introduced the changes to the way of application of the test in Ukraine. Thus, in terms of TP control, the analysis of the business purpose was extended and now also implies analysis of the alternative options available to the parties acting with commercial rationality if they were not related. In addition to non-recognition of a transaction for taxation purposes, the tax authorities received the right to substitute the conditions of the transaction between related parties with an alternative transaction they deem commercially rational given the facts of the case.

New business purpose test rules for transactions with non-residents that fall under the list of “low tax” states (territories) or the list of organizational forms of non-residents (covering fiscally transparent entities) will be in force from 1 January 2022.

According to the current rules transactions with such non-residents are subject to special 30% adjustment. This adjustment means that the profit tax base should be increased by 30% of the value of the goods (services) purchased from or supplied to such non-residents unless taxpayers proves that the relations are at arm’s length (although such transactions are not subject to standard TP rules).

From 2022 the Ukrainian tax authority will receive the right to also control the business purpose of such transactions. And in case the tax authority finds that a transaction lacks reasonable economic purpose, the profit tax base would be increased by the entire value of the goods (services) thus purchased or supplied. In other words, absence of the business purpose would effectively mean 100% adjustment on transactions with such listed non-residents.

It is advisable not to ignore these new rules and get properly prepared as the tax implications may be material.

If you would like to know more about the new business purpose test in Ukraine, please visit the homepage of WTS Tax Legal Consulting, LLC, the exclusive representative of WTS Global in Ukraine.

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Transfer pricing rules before 2018

Transfer pricing (TP) rules were implemented into Ukrainian tax law from 2013. However, before 2018, permanent establishments (PEs) were a blind spot for TP control.

According to the Tax Code of Ukraine, non-residents that conduct business activity in Ukraine via a PE pay corporate profit tax. However, TP rules that were in force before 2018 did not provide any special rules for PEs. It was unclear whether PEs in Ukraine are subject to TP reporting requirements alongside regular corporate profit tax reporting, and what transactions of PEs in Ukraine may be recognised as being subject to TP control.

It was clear, however, that the Ukrainian TP rules lacked any legal basis to control dealings between PEs and non-residents establishing such PEs. This was due to the definition of controlled transactions for TP purposes, which did not provide grounds to extend the control to dealings between parts of the same legal entity.

This ambiguity meant that PEs of non-residents mostly ignored TP control in Ukraine, even though, under the rules existing before 2018, some PE transactions might have been recognised as being subject to TP control: for instance, if a PE had dealings with a foreign related party of the non-resident that established the PE.

Introduction of TP reporting for PEs in Ukraine

Starting from 2018, Ukrainian TP rules were supplemented with the new type of controlled transactions, namely, transactions between a non-resident and its PE in Ukraine. The Ukrainian Tax Code prescribes a special value threshold for recognising such transactions as controlled, namely UAH 10 million (roughly EUR 305,000), without applying the turnover-based threshold which is provided for enterprises.

Thus, 2018 became the first TP reporting period for PEs in Ukraine.

However, there was still some ambiguity due to the lack of proper guidance from the Ukrainian authorities on how PEs in Ukraine should conduct the analysis in practice and comply with the reporting requirements. Moreover, it was unclear how the results of such TP analysis may be applied to the corporate profit tax base calculation.

The Tax Code of Ukraine (sub-para.141.4.7) provided for the following options to calculate profits that non-residents derive through their Ukrainian PEs:

• The profit is calculated according to the general rules of the Tax Code, assuming that the PE is deemed a taxpayer separate from the non-resident and operates independently.
• If a non-resident operates both in and outside of Ukraine and does not determine profit derived from Ukraine, a separate balance sheet for its Ukraine-related activity should be prepared. This balance sheet should be approved by the tax authority at the location of the PE.
• If it is impossible to reliably calculate the profit sourced in Ukraine, then the profit is calculated as Ukraine-sourced income of the PE less costs, calculated by applying a 0.7 coefficient to such income. In other words, the profit is effectively calculated as 30% of the income received by the PE without needing to allocate and prove costs related to the PE activity.

PEs filed special reports to declare their profit tax liabilities using one of the mentioned methods. Many PEs opted for the approach calculating profit as 30% of income due to its simplicity.

After extending TP control to dealings between non-residents and their PEs in Ukraine, the above rules were supplemented with the reference that the profit under all such methods should be calculated with due regard to Ukrainian TP rules. It was not clear though how such rules should have been applied for the cases when the profit is calculated as 30% of income.

Recent changes to calculation of profit

The rules of profit calculation by PEs in Ukraine were changed once again by Law #466-IX, which came into force in May 2020. From this date onwards, the special rules of profit calculation by PEs, including the calculation method applying the 0.7 coefficient, were deleted from the Tax Code.

Instead, the new rules stipulate that the profit should be calculated following the arm’s length principle. Such profit should be in line with the profits of independent entities carrying out the same or similar activity as if such PE operated separately from the non-resident. The amount of any profit should be calculated according to Article 39 of the Tax Code setting forth Ukrainian TP rules.

Two-step analysis recommended

Yet this change has not made the situation clearer. Ukrainian TP rules are primarily designed for application by enterprises and do not contain any special rules which may be followed by PEs to determine their profits. Also, there is no official clarification from the authorities so far.

We understand that the only reliable way would be to follow the OECD-authorised approach to allocate profits to PEs. It implies that the two-step analysis should be carried out:

• firstly, hypothetical dealings between the non-resident and its PE should be identified, and
• secondly, such dealings should be priced by applying TP methodology.

Ukrainian taxpayers are required to file corporate profit tax returns quarterly (with some special exceptions). Therefore, it is likely that the forward-looking TP analysis should be implemented, otherwise, in many cases PEs in Ukraine would lack the information necessary to draft the return.

Yet these are just preliminary thoughts on the matter. Hopefully, taxpayers will receive proper clarification from the authorities very soon.

Clarification still required

Such clarification is desperately required due to the lack of appropriate transition rules in Law #466-IX. This change occurred in the middle of the year and a lot of PEs have already reported their profits for the first quarter applying the previous mechanisms. So, the question arises of how to file the reports after the changes. Thus far, the tax authorities have just recommended filing the ordinary profit tax return instead of the report on profit of the PE. However, the tax authorities have not shared their vision on how the data from previously filed reports should be transferred to such regular profit tax returns. This is especially important in the cases when the profit was calculated as 30% of income.

Hopefully, the authorities will very soon produce clear guidance that can be followed. Otherwise, the only option for PEs in Ukraine would be to use the results of the TP analysis for previous years and adapt these for the current profit tax reporting. If a PE has not conducted any such analysis, it is highly recommended to do so urgently.

If you would like to know more about the latest TP-rules for PEs in Ukraine, please visit the homepage of WTS Tax Legal Consulting, LLC, the exclusive representative of WTS Global in Ukraine.

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Earlier, the Cabinet of Ministers of Ukraine also changed the list of legal forms of non-residents that do not pay profit tax and/or are not tax residents in the countries of their registration. In our article, we take a detailed look at all the TP-related changes in Ukraine.

Implementation of BEPS actions

A large portion of the TP-related changes in Ukraine concerns the long-awaited implementation of the BEPS Plan actions into the country’s tax law. Thus, the new legislation adopts the three-level structure of TP documentation according to Action 13 of BEPS. Hence, TP documentation shall consist of a master file, local file and a Country-by-Country Report (CbCR). In addition, Ukrainian entities of multinational companies (MNCs) will have to file notification about their participation in international groups of companies.

The suggested TP-related changes in Ukraine are generally in line with BEPS recommendations. Yet there are also some differences. For instance, although it envisages a general threshold of EUR 750 million and the presence of one circumstance, listed in the corresponding article, for submitting a CbCR, the master file may be requested by Ukrainian tax authorities if the annual consolidated group revenue is equal to or exceeds EUR 50 million.

The Draft Law introduces new penalties for failure to comply with the added reporting requirements, which may be quite significant. They are linked to subsistence wage amounts, which are gradually revisited. For example, the penalty for failure to submit a CbCR equals 1,000 times the subsistence wage, which would currently amount to UAH 2 million (roughly EUR 74,000 under the current exchange rate).

Business purpose

An important new feature is the introduction of the principle of business purpose for transactions. It means that taxpayers will be obliged to prove in TP documentation that controlled transactions on acquiring works (services), intangible assets, and items other than goods have a clear business purpose. The tax authorities may disregard transactions without a reasonable business purpose when calculating the base for profit tax.

Deemed dividends

According to the adopted TP-related changes in Ukraine, the amount of TP adjustment that increases the tax base in Ukraine may be treated as a deemed dividend distribution. Such dividend distribution would be subject to withholding tax (WHT) in Ukraine at the regular WHT rate of 15%, unless otherwise provided for by applicable double tax treaties.

Independence threshold

The threshold for recognising parties as related parties would be raised to 25% as compared to the current threshold of 20%. This change would bring Ukrainian legislation closer to dominant international practice.

List of business transactions that fall under TP control

It is specified that taxpayers should also report on transactions that reduce their income and/or financial result as a result of the full/partial, irrevocable/temporary transfer of functions together with (or without) tangible and/or intangible assets, benefits, risks and opportunities to another taxpayer (to another person), regardless of whether such transactions are reflected in accounting or not.

Special TP-related changes in Ukraine for commodities

The Draft Law introduces new rules for transactions with commodities. Namely, taxpayers would need to apply “quoted prices” for the TP analysis of some transactions with commodities. Quoted prices are defined as pricing data, which includes exchange quotations and price indices published by recognised agencies, statistical and government agencies. Also, taxpayers carrying out such transactions with commodities should notify the tax authorities upon the conclusion of the relevant contract.

The list of commodities subject to these rules as well as the procedure for applying the quoted prices would be adopted by the Cabinet of Ministers of Ukraine.

Introduction of rules for controlled foreign corporations

There are also some other changes, including the introduction of rules for controlled foreign corporations (CfC), which are new to Ukrainian legislation. In particular, along with the general provisions and explanations, it is stated that the tax authority may oblige the controlling entity to provide TP documentation on the transactions of CfC with related non-residents or with non-residents that fall under the Ukrainian list of low-tax states or the list of legal forms (covering fiscally transparent entities), if the total volume of transactions with such entity exceeds UAH 10 million (roughly EUR 345,000) per calendar year and the annual income of the CfC exceeds UAH 150 million (roughly EUR 5.2 million) per calendar year. If the TP documentation and/or copies of primary documents are not submitted, the tax authority increases the pre-tax profit of the CfC by 30% of the income/expenses for which the TP documentation/copies of primary documents were not submitted.

Also, the controlling entities are obliged to submit a report on the CfC and reports on the acquisition or termination of participation in the CfC.

Adjustment of financial result for tax (reporting) period

The Draft Law provides for the 30% adjustment of the financial result of the taxpayer, not only when purchasing but also when selling goods (including fixed assets), works and services (transactions that are not deemed controlled) to non-residents that fall under the Ukrainian list of low-tax states or the list of legal forms (covering fiscally transparent entities). However, such requirements would not be applicable if the transactions are controlled for TP purposes, or even for uncontrolled transactions, if the taxpayer still opts to confirm that the pricing is at “arm’s length”.

Also, the financial result of the tax (reporting) period should be increased by the amount of expenses incurred by the taxpayer in transactions with non-residents if such transactions do not have a business purpose.

Introduction of all the changes specified above

If enacted, such changes will come into effect from 1 January 2021. Even if the President of Ukraine vetoes the Draft Law, we expect that the BEPS-related amendments will still be introduced soon as a separate law comprising most of the rules outlined above.

Important changes to the list of legal forms of non-residents

The list of legal forms of non-residents that do not pay profit tax and/or are not tax residents in the countries of their registration has been changed as well.

Starting from 1 January 2020, the list of such legal forms of non-residents registered in Austria, Germany and Poland is as follows (additions to the list marked with italics):

The Republic of Austria

The Federal Republic of Germany

The Republic of Poland

For now, such new lists of legal forms of non-residents should be considered by the taxpayers when preparing TP documentation and reports on TP, as well as for the purpose of the 30% adjustment of the financial result. But, as we can see from Draft Law No. 1210, the amendments to such lists could affect TP rules significantly from 2021.

If you would like to know more about the latest TP-related changes in Ukraine, please visit the homepage of WTS Tax Legal Consulting, LLC, the exclusive representative of WTS Global in Ukraine.

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Supply of software products and IT services is the most rapidly developing economic sphere in the world and, in particular, in Ukraine. In 2017, Ukraine was recognized as the best country to provide IT outsourcing services (according to the data provided by Global Sourcing Association), with a total export volume of approximately USD 3.6 billion (third place in contribution to the GDP of Ukraine after agriculture and metallurgy).

Considering the high level of competition on the world market of software development, the Ukrainian government introduced a few tax benefits for transactions on supply of software products to maintain the competitiveness of domestic software developers.

According to the provisions of the Tax Code of Ukraine, the supply of software products as well as transactions with software products for which the payment is not deemed to be royalties are temporarily VAT exempt until the end of 2022. This exemption does not cover transactions on the transfer of software rights, payments for which are considered as royalties, as such transactions are VAT-exempt under the general rule.

Definition questions of supply of software products

Taking into account that software products are constantly changing and evolving, in order to apply the above VAT exemption, it is necessary to understand what is included in “software products”. Based on the definition given in the Tax Code itself, “software products” include the results of computer programming in the form of operating systems, computer programs or their components, any changes, updates, add-ons for computer programs, websites, cloud-based services, as well as cryptographic information security tools.

As no questions usually arise when it comes to the supply of operating systems or computer programs, some problems may still appear in case of the supply of cloud-based services. Local tax authorities further explain that the supply of cloud-based services is VAT exempt when the customer gets the right to use the software as an end-user for its own purposes (e.g., storage of data or online accounting services). Whereas the mere provision of information or specific data with the use of cloud-based services without granting the customer actual access to the software itself will not entitle software suppliers to apply the VAT exemption.

What about accompanying services?

Another issue that may arise is that contracts between software suppliers and their customers are not always limited to the supply of software products but also include the provision of support-related and other accompanying services. If such accompanying services are indistinguishably linked to the software products and included in their price (e.g., installation, setup, testing, fixing bugs, etc.), they are also exempt from VAT. But in cases when accompanying services are not included in the price of software products and/or provide for further technical assistance in the course of the use of the software, such services are not considered VAT-exempt. In the latter case, the supply of software products and the supply of accompanying services must be split in the contract and regarded as separate transactions, one of which will be VAT-exempt and the other not.

In order to avoid any mistakes with accruing and paying VAT for transactions on the supply of software products, the parties should thoroughly stipulate the contractual terms, determine whether the supplied software products and accompanying services are covered by the VAT exemption and split the contract if at least one of the transactions within its framework is subject to VAT.

If you would like to know more about VAT exemption for supply of software products in Ukraine, please visit the homepage of WTS Tax Legal Consulting, LLC, the exclusive representative of WTS Global in Ukraine.

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In Ukraine, non-resident individuals are subject to personal income tax (PIT) in respect of their Ukrainian-source income. According to the Tax Code of Ukraine, Ukrainian-source income means any income attributable to Ukraine, not limited to the income paid in/from Ukraine. For example, the remuneration of an employee earned due to any of their activities in Ukraine, including remuneration received from a foreign employer, shall be considered as Ukrainian-source income. Furthermore, Ukrainian-source income includes interest, dividends, royalties and other passive income, paid by residents of Ukraine, income from the leasing of property located in Ukraine, etc.

The standard PIT rate is 18%. With few exceptions, it is applied to all payments made by an employer (including foreign) in relation to employment exercised in the territory of Ukraine. With regard to dividends, the tax rate differs depending on the status of a payer. Thus, dividends paid by residents/payers of corporate income tax (except joint investment institutions) are taxed at a rate of 5%, while dividends paid by non-residents, joint investment funds and non-payers of corporate income tax are subject to a rate of 9% PIT. All other passive income is taxed at the standard rate of 18%.

Also military tax applies to non-residents

In addition to the PIT, in August 2014 a temporary military tax was introduced in Ukraine. It is accrued at a rate of 1.5% to the same taxable base as the PIT. Thus, non-residents’ income, originating from Ukraine, is subject to the military tax.

It is worth mentioning that the legitimacy of the military tax is rather controversial. However, in order to avoid disputes with tax authorities the military tax is assessed and paid in most cases. As to the “temporary” nature of the military tax, it will be effective as long as the reformation of the Ukrainian Military Forces lasts. At the same time, the legislation does not determine the period of reformation or when it should be completed.

Increase of individuals’ tax audits

The procedure for the assessment and payment of the PIT and the military tax depends on the status of the income payer, as well as the type of income paid. For example, if remuneration for activities performed in Ukraine is paid to a non-resident by a resident (e.g. a Ukrainian legal entity employs a foreigner), then taxes are assessed and paid on behalf of the non-resident by the Ukrainian resident. If a salary is paid to a non-resident by another non-resident, then an annual declaration procedure has to be applied. In such cases non-residents are obliged to submit an annual tax return by 1 May of the year following the year in which the PIT and the military tax should be accrued. The respective self-assessed taxes shall be paid no later than 1 August of the year following the reporting year.

Nevertheless, at this stage (once the tax return is submitted and taxes are paid) the taxation issues may not be over for the taxpayer. Thus, submitting the tax return might be followed, firstly, by the tax authorities’ audit, during which the accuracy of the calculation of self-assessed taxes is checked as well as the correct completion of the tax return. Furthermore, the tax authorities can ask a taxpayer to provide documents and information related to the occurrence of income, calculation and the payment of taxes. Documents confirming the authenticity of other information specified in the tax return (in particular regarding available movable and immovable property) might also be requested by the tax authorities. In 2018, an increase of individuals’ tax audits is being observed.

1,095 days

Regarding the retention of documents, according to the Tax Code of Ukraine a taxpayer is obliged to retain tax-related documents for 1,095 days following the deadline for submission of the tax return for the reporting year (and if it was filed later, following the day of its actual submission). If the tax return was not submitted in breach of the provisions of the Tax Code of Ukraine, then the specified period of 1,095 days shall not apply, and the documents must be kept regardless of this period.

In practice there are many issues, since not every taxpayer has the required documents, or their documents are not completed correctly (e.g. notarisation of documents and other requirements concerning their form prescribed by the legislation). In the latter case, there is a risk that such documents will not be recognised by the tax authorities as proof of the occurrence of income, the authenticity of other information specified in the tax return, etc.

If the tax authorities find a violation based on the analysis of the documents provided, an audit in respect of a taxpayer may trigger negative consequences. According to Ukrainian legislation, a taxpayer can be held financially responsible (tax liabilities and penalties are assessed), and subject to administrative and criminal charges. As to criminal liability, it is stipulated for the tax evasion in the amount of UAH 881,000 (roughly EUR28,500) as of 2018. ‘Tax evasion’ includes actions such as the failure to submit documents related to the calculation and payment of taxes (tax returns, etc.), concealment of taxation objects (non-declaring of the received income in whole or in part, etc.), undervaluation of taxation objects, or the submission of false information or documents certifying the right of an individual to a tax credit or tax social benefit.

If you would like to know more about the income taxation of non-residents in Ukraine, please visit the homepage of WTS Tax Legal Consulting, LLC, the exclusive representative of WTS Global in Ukraine.

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