Provision of the support to the Ministry of Finance and the State Tax Service in the establishment of automatic information exchange
EU4PFM experts continue to support the Ministry of Finance and the State Tax Service in the establishment of automatic information exchange.
On November 16, 2020, the Ministry of Finance of Ukraine shared on its website a draft order of the Ministry of Finance of Ukraine “On approval of the form and procedure for completing the Report of the international group of companies in terms of countries” This document was developed by the Ministry of Finance, the State Tax Service with the participation and active support of EU4PFM experts.
The draft is available in the section ” Legislation / Draft Regulatory Acts Discussion”, following the link:
https://mof.gov.ua/uk/regulatory_acts_draft_for_discussion_2020-408
The draft form and the Procedure for Completing the Notice on Participation in an International Group of Companies are expected to be published in the nearest future.
To recall, on January 1, 2017, Ukraine joined the Inclusive framework on BEPS within the Organization for Economic Cooperation and Development (OECD) and undertook the obligation to implement the minimum standard of the Action Plan to combat domestic tax base erosion and profit shifting.
Among the measures that are mandatory for Ukraine to comply with the minimum standard is Action 13 “Guidance on Transfer Pricing Documentation and Country-by-Country Reporting.”
This action involves the introduction of a three-level structure of documentation: Master file, Local file, Country-by-Country Report.
The necessary set of legislative norms was introduced by the Law of Ukraine № 466-IX “On amendments to the Tax Code of Ukraine regarding improvement of tax administration, elimination of technical and logical inconsistencies in tax legislation”, adopted as of 16.01. 2020. The Work to prepare bylaws is currently underway.