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The Ukrainian Government has undertaken a comprehensive analysis of 220 countries' corporate tax regimes to improve the efficacy of its newly-implemented "Law amending the Tax Code of Ukraine regarding transfer pricing."
The law seeks to prevent tax leakage to countries with lower corporate tax rates than Ukraine. A list of 92 countries that have a corporate tax rate five percentage points lower than Ukraine's has been drawn up for increased oversight, in particular of cross-border transactions between connected parties valued over UAH50m (USD6m).
The Government believes the new transfer pricing framework, approved on September 1, 2013, is yielding results, stemming flows of income to lower tax territories. It has estimated that, when fully operational, it will boost Ukrainian corporate tax revenues by around UAH12bn annually from 2015. Preliminary estimates, published by Ukraine's Cabinet on December 26, 2013, suggest that revenues worth UAH5.7bn were secured during 2013.
"The mutual victory of business and the Ministry this year was the adoption of the draft law on transfer pricing. We are still working on its enforcement, but the protective effect is already noticeable. The exports to offshores have been halved since early 2013," Oleksander Klymenko, Minister of Revenue and Duties, reported.
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