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IFA Ukraine Discussed Latest Anti-offshore Practice in Ukraine

28 October, 2014, Kyiv, Ukraine

Seminar participants discussed latest developments with regard to Action Plan on Base Erosion and Profit Shifting (BEPS), upcoming fundamental anti-offshore changes in RF, application of doctrinal approach in Ukrainian court practice, as well as current initiatives of the Ukrainian Government to counter harmful tax practices.

When opening the Seminar, Olena Voznyuk, IFA Ukraine President denoted the importance of anti-offshore measures both at the local and international levels in a view of strengthening globalization: "Although not directly referred to BEPS framework, Ukraine should nonetheless pay specific attention to its preparation and implementation, since Plan's outcomes will definitely have the impact on Ukraine in the near future, especially for multinational companies operating in Ukraine".

Oleg Shmal, Senior Manager, PwC Ukraine provided detailed overview of OECD deliverables addressing seven of the focus areas in BEPS Action Plan. According to Oleg, BEPS will become relevant to Ukraine already in few years, and the forthcoming important decisions on Action Plan's implementation may be expected at the next G20 Leaders' Summit in Brisbane in November 2014.

Pavlo Selezen, PhD in Law, Senior Research Fellow of the National Centre for Tax Issues Research examined BEPS initiatives focused on preventing double tax treaty abuse. In particular, Pavlo noted that in a view of inexplicit wording of GAAR requirements and in order to balance the interests of tax payers and tax authorities it is proposed to oblige tax authorities to prove that receiving treaty benefits is the only purpose of tax payers' undertaking.

Oleksandr Maydanyk, Senior Associate, Egorov Puginsky Afanasiev & Partners Ukraine illustrated application of doctrinal approach (business purpose and substance over form doctrines) with regard to cross-border transactions based on Ukrainian court cases (Auchan, ArcelorMittal). When commenting on court cases ruled in favor of taxpayers, Deputy Head of Administrative Department of the High Administrative Court of Ukraine Anton Polianychko assumed that tax authorities might have succeeded in the disputes if focused not only on domestic aspects, but also on international level.

Oleksii Zadorozhnyi, Head of Division of Methodology of Corporate Profit Tax, Department of Tax Methodology, State Fiscal Service of Ukraine informed Seminar attendees about anticipated changes to Ukrainian anti-offshore legislation (thin-cap rules, taxation of royalty, etc), amendments to Transfer Pricing rules, possible impact of BEPS on Ukraine, as well as answered participants' questions.

The panel on latest tendencies in Russian anti-offshore legislation was joined by Russian colleagues from ROS-IFA via telecom. During 1,5 hour session Victor Machekhin, Linklaters, Head of Tax Practice, Boris Bruk, Dentons, Counsel, and Andrey Kirillov, Baker Tilly Russaudit, Head of International Projects, Tax and Legal Department commented on specifics of the Russian Government approach towards deoffshorization starting from 2014, as well as on reaction of Russian businesses to anticipated changes. 

The event was attended by representatives of State Fiscal Service of Ukraine, Ministry of Finance of Ukraine, High Administrative Court of Ukraine, National Center for Tax Issues Research, multinational companies, leading law and audit firms.

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