Ukraine: Extending the list of “low-tax” jurisdictions for the purposes of transfer pricing

The Cabinet of Ministers of Ukraine adopted a new extended list of “low-tax” jurisdictions on 27 December 2017. The list now includes, for instance, jurisdictions such as Georgia, Estonia, Iran, Latvia, Malta, UAE and Singapore (the full list of countries).

Transactions carried out by Ukrainian residents with counterparties from the listed “low-tax” jurisdictions are subject to transfer pricing control in Ukraine (subject to de minimis thresholds), limitations on deductibility and other anti-tax avoidance instruments.

The new list entered into force on 1 January 2018.