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TAXES
2016
UKRAINEIN
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Schedule 1.
Schedule 2.
Corporate income tax
Value-added tax
Simplified tax system
Personal income tax
Single social contribution
Military duty
Excise tax
Real estate tax
Transport tax
Environmental tax
Rent payments
Duties
List of double taxation agreements of Ukraine
List of offshore jurisdictions
TABLE
OF CONTENTS
CORPORATE
INCOME TAX
1
1. CORPORATE INCOME TAX 4
Taxpayers
Corporate Income Tax (CIT) is paid by the resident companies, which receive
income in Ukraine as well as abroad. CIT is also paid by the non-resident
companies, which receive income from Ukrainian sources.
Rate
Currently, a flat rate of 18% is established for all CIT taxpayers.
However, for some activities a separate rate is applicable. These include:
•	 3% rate for insurance activities regarding the non-life insurance;
•	0% rate for insurance activities regarding the long-term life insurance,
voluntary medical insurance and non-state pension schemes;
•	 10% rate for lotteries and gambling activities using gaming machines;
•	0%, 4% and 12% for non-resident insurers based on insurance
agreement (depending on the insurance accident case);
•	6% for a freight amount paid by a resident to a non-resident under
freight contracts;
•	15% for residents or permanent representative offices in Ukraine,
which make payments to non-residents from the income derived from
Ukrainian sources of origin;
•	20% for residents, which make payments to non-residents for
advertising production or its distribution.
Tax base
The CIT base is the income derived from Ukrainian sources of origin and
abroad. The amount of tax is determined by adjustment of financial result
(profit or loss) before tax, as calculated in accordance with the Ukrainian
accounting standards or IFRS.
Peculiarities of taxation
Adjustment of financial results
Adjustment of financial results is possible by way of:
1) Amortization
The financial result before tax is increased by:
•	the amount of the accrued depreciation of fixed assets or intangible
assets pursuant to the Ukrainian accounting standards or IFRS;
•	the amount of write-off and impairment of fixed assets and intangible
assets, included in the expenses of the reporting period in accordance
with the Ukrainian accounting standards or IFRS;
•	the amount of residual value of a separate item of fixed assets or
intangible assets defined by the Ukrainian accounting standards or IFRS,
in the event of liquidation or sale of such asset.
1. CORPORATE INCOME TAX 5
The financial result before tax is decreased by:
•	 the amount of the depreciation of fixed assets and intangible assets;
•	 the amount of residual value of a separate item of fixed assets or intan-
gible assets, defined by tax accounting in the event of liquidation or sale
of such asset;
•	 the amount of revaluations and gains from the recovery of fixed assets
and intangible assets value in the amount of losses from the previous
period write-off and impairment of such assets in accordance with the
Ukrainian accounting standards or IFRS.
2) Reimbursement for future expenses
The financial result before tax is increased by:
•	 the amount of expenses on accrued provisions for future expenses and
payments in accordance with the Ukrainian accounting standards or
IFRS.
The financial result before tax is decreased by:
•	the amount of realization of accrued provisions or future expenses and
payments, accrued in accordance with the Ukrainian accounting stand-
ards of IFRS;
•	 the amount of provision reduction if it has increased the financial profit
(loss) before tax.
3) Doubtful debts
The financial result before tax is increased by:
•	 the amount of doubtful debts accrued in accordance with the Ukrainian
accounting standards or IFRS;
•	 the amount of receivables write-off that does not fulfil the criteria of bad
debt over debts allowance.
The financial result before tax is decreased by:
•	 the amount of doubtful debts allowance reduction if it has increased
the financial result before tax in accordance with the Ukrainian account-
ing standards or IFRS.
Some types of profit are not included in the overall taxable income. These
include:
•	 the income from the interest accrued on securities of the Ministry of
Finance of Ukraine and the NBU’s debt obligations;
•	 the income received by non-residents as the interest accrued on gov-
ernment securities or municipal bonds or debt securities guaranteed by
the state;
•	 the body of the deposit at a bank or non-bank financial institution;
•	 the principal amount of repayable returnable financial aid provided by a
taxpayer to other persons. The principal amount of repayable financial
aid received by a taxpayer;
•	 the investment profit from transactions with debt obligations of the
NBU and treasury obligations of Ukraine;
•	 the income from international financial organizations under the frame-
work of implementation of energy efficiency and energy saving projects.
Taxation of non-residents
The income of non-resident legal entities derived from Ukrainian sources of
origin is taxed by CIT at the rate of 15%. The CIT tax base is the income from
dividends, royalties, freight, the proceeds of engineering, leasing and rent,
profits from sale of real estate, securities and corporate rights, the proceeds
of joint activities and entertainment activities, etc.
In relation to the income from Ukrainian sources of origin, the following
rates apply:
In certain cases, the lower tax rate might apply under the double taxation
agreements. Ukraine has valid double taxation agreements with approxi-
mately 75 countries (see Schedule 1). It should also be noted that double
taxation agreements with specific countries may provide for more favour­
able taxation arrangements.
Transfer pricing
For the purposes of correct CIT taxation, the control has been established
over related-party transactions. In addition, such control is exercised over
transactions with non-residents in low-tax jurisdictions. The list of such
countries is specified by the Cabinet of Ministers of Ukraine and provided in
Schedule 2.
Low-tax jurisdictions are determined on the basis of the following criteria:
•	the general CIT rate in such countries is by 5 or more percentage points
lower than in Ukraine;
•	Ukraine does not have any agreements on information exchange with
such countries.
The transfer pricing control is exercised over transactions, where:
•	the taxpayer’s revenue exceeds UAH 50 million*
for the tax year;
•	the annual volume of the transactions with one counterparty (related
person) exceeds UAH 5 million.
1. CORPORATE INCOME TAX 6
Dividends 15%
Interest 15%
Royalty 15%
Freight 6%
Other profits from Ukrainian sources of origin 15%
* As of 30 June 2016 the National Bank of Ukraine established its official currency exchange rate at UAH 24.85 per one US dollar.
Fines for failure to submit a report on the controlled transactions and re-
spective documentation on transfer pricing are as follows:
•	300 minimal wages*
for failure to submit the report on controlled trans-
actions;
•	1% of the amount of transactions omitted from the report, but no more
than 300 minimal wages for all undeclared transactions;
•	3% of the amount of transactions in respect of which transfer pricing
documentation was not submitted, but no more than 200 minimal wages.
Thin capitalization rules
In order to prevent tax base erosion and profit outflow from the country,
there are the thin capitalization rules effective in Ukraine.
Under the thin capitalization rules, expenses of the resident in the current tax
period include the amount of interest paid on loans, which does not exceed
50% of profits, expenses on repayment of interests. It should be noted that a
non-resident is deemed to be a related party if the amount of taxpayer’s liabili-
ties with such non-resident exceeds the equity ratio by more than 3.5 times.
1. CORPORATE INCOME TAX 7
* Currently, one minimal wage in Ukraine amounts to UAH 1,450. Starting from 01 December 2016 the minimal wage will
amount to UAH 1,550. The minimal wage is specified each year in the state budged of Ukraine.
VALUE-ADDED
TAX
2
2. VALUE-ADDED TAX 9
Taxpayers
The taxpayer is obliged to register as a VAT payer if the aggregate value of
supplied goods or services exceeds UAH 1 million for the last 12 months.
However, if the value of taxable transactions does not exceed UAH 1 million,
the voluntary registration as a VAT payer is available.
Rate
The VAT rate is 20%. For pharmaceutical products, the VAT rate is 7%. It
should be noted that 0% VAT rate is applied to export of goods in the cus-
toms regime from the territory of Ukraine.
Tax base
VAT is applied to transactions on supply of goods and services on the cus-
tom territory of Ukraine, as well as to transactions related to import and
export of goods in Ukraine. In addition, services on international transporta-
tion of passengers and luggage by sea, river and air transport are also sub-
ject to VAT.
The following transactions are not subject to VAT:
•	 issue of securities by business entities;
•	 provision of insurance services by the licensed organizations;
•	provision of services of payment systems related to transfer of funds,
encashment, cash management services, attraction, placement and
refund under loans, deposit and securities management agreements,
management and assignment of claims to financial institutions;
•	 payment of salary in cash;
•	 provision of educational services;
•	 provision of administrative services;
•	 provision of banking services;
•	 import and export of goods to the amount less than EUR 150;
•	 payment under lease or concession agreements;
•	reorganization (merger, accession, division, separation and transforma-
tion) of legal entities.
Peculiarities of taxation
VAT refund
Following cancellation of automatic VAT refund in 2016, there are two regis-
ters of budget VAT refund.
are not subject to insolvency procedures. are listed in the Unified State Register of Legal Entities and
Individual Entrepreneurs with their profile containing no
data on:
•	 failure to provide confirmation of submitted data;
•	 failure to establish presence at the registered office
location;
•	 adoption of resolution in relation to separation or
termination of a legal entity;
•	 declaring constitutional documents or changes to
constitutional documents of a legal entity as fully or partially
null and void;
•	 termination of the state registration of a legal entity or
individual entrepreneur.
have fixed assets with the residual book value exceeding the
amount of tax claimed for refund by more than three times;
or
received a financial guarantee for up to one year from the
banking institution;
or
perform transactions on export of goods from the customs
territory of Ukraine under the customs regime, whose
share in the previous reporting 12 consecutive tax periods
(months) together is at least 40 percent of total shipments.
The second register is aimed at taxpayers who do not meet the abovemen-
tioned requirements.
Special regime for agricultural producers
Special taxation regime for agricultural producers is valid until 1 January
2017. Such regime provides that:
•	under transactions with agricultural goods/services (except for grain
and industrial crops, as well as livestock transactions), 50% of VAT shall
be paid to the state budget and 50% of VAT shall be credited to the spe-
cial VAT account of the agricultural producer;
•	under transactions with grain and industrial crops, 85% of VAT shall be
paid to the state budget and 15% of VAT shall be credited to the special
VAT account of the agricultural producer;
•	under transactions with livestock, 20% of VAT shall be paid to the state
budget and 80% of VAT shall be credited to the special VAT account of
the agricultural producer.
2. VALUE-ADDED TAX 10
The first is for the taxpayers, which meet the following criteria:
SIMPLIFIED
TAX SYSTEM
3
3. SIMPLIFIED TAX SYSTEM 12
І group IІ group ІII group ІV group
Taxpayer
Number of employees
Max. profit per year
Tax rate
Type of activities
Private entrepreneur
Retail sale of goods at
market places, provision of
consumer services to citizens
Provision of services
(including consumer services)
to the single tax payers and
citizens; manufacturing and
sale of goods; restaurant
activities, etc.
All types of business activities
permitted under single tax
rules
Agriculture producers with the share of
agricultural commodity production in
the previous tax year at least 75%
Private entrepreneur Private entrepreneur / legal entity Private entrepreneur / legal entity
0
UAH 300,000
Up to 10% of minimal wage
Up to 10
UAH 1.5 million
Up to 20% of minimal wage
No restrictions
UAH 5 million
3% of income (VAT excluded);
5% of income (VAT included)
No restrictions
—
Depending on the category of land, its location
and amounts (in per cent of the tax base):
• for arable land, hayfields and pastures — 0.81;
• for arable land, hayfields and pastures located
in mountainous areas and marshy woodland
areas — 0.49;
• for perennial plantations — 0.49;
• for perennial plantations located in mountainous
areas and marshy woodland areas — 0.16;
• for lands of water fund — 2.43;
• for arable land, hayfields and pastures on closed
soil — 5.4.
With the aim of facilitation and easement of small and medium business accounting, Ukraine introduced special taxation terms for such businesses.
The taxpayers, both private entrepreneurs and legal entities, may choose to apply for a simplified taxation system in one of the following categories:
3. SIMPLIFIED TAX SYSTEM 13
Peculiarities of taxation
Agricultural producers
Legal persons have the right to choose the fourth group of the single tax
provided that their share of agricultural commodity production in the previ-
ous year amounted to at least 75%. This is applicable to:
•	all entities separately, which carry out merger or accession. In this case, it
is possible to become a single tax payer in the year of creation, if the share
of agricultural commodity production for the previous tax year by all com-
modity producers involved in their creation equals to or exceeds 75%;
•	each individual entity created by split-up or spin-off. In this case, it is
possible to become a single tax payer from the next year, if the share of
agricultural commodity production for the previous tax year equals to
or exceeds 75%;
•	an entity created by transformation. In this case, it is possible to be-
come a single tax payer in the year of transformation, if the share of
agricultural commodity obtained for the previous tax year equals to or
exceeds 75%.
Newly created agricultural commodity producers may be single tax payers
from the next year, if share of agricultural commodity production obtained
for the previous tax year equals to or exceeds 75%.
PERSONAL
INCOME TAX
4
Taxpayers
The personal income tax (PIT) is paid by resident and non-resident individu-
als.
Rate
PIT rate is 18%, while PIT rate for dividend payments is 5%.
Tax base
The monthly (annual) taxable income of taxpayer does not include:
•	 the interest accrued on certain state securities issued by the NBU;
•	the alimony received in accordance with the court ruling or voluntary ar-
rangement of the parties as provided by the Family Code of Ukraine;
•	 body of the deposit at a bank or non-bank financial institution;
•	 the income of private entrepreneur, which is subject to single tax;
•	insurance payments, pension payments, etc., received under the long-
term life insurance agreement;
•	 amounts forgiven (annulled) by the lender;
•	the income from financial (including international) organizations under
the framework of implementation of energy efficiency and energy sav-
ing projects;
•	the amount of property and non-property contribution to the charter
capital of a legal entity;
•	 the charity aid amounts.
4. PERSONAL INCOME TAX 15
Residents Non-residents
Monthly (annual)
taxable income
Income from
Ukrainian
sources of origin,
taxable at the
time of its accrual
(payments,
compensation)
Income from
foreign sources
of origin
Monthly (annual)
taxable income
from Ukrainian
sources of origin
Income from
Ukrainian
sources of origin,
taxable at the
time of its accrual
(payments,
compensation)
5.	SINGLE SOCIAL CONTRIBUTION
SINGLE SOCIAL
CONTRIBUTION
5
Rate
The single social contribution rate is established at 22%. However,
the maximum taxable amount of the single social contribution shall
not exceed 25 minimal wages.
Tax base
The single social contribution is paid from wages and bonuses of
employees as well as income of private entrepreneurs.
Taxpayers
The single social contribution is paid by the employers, private
entrepreneurs, self-employed citizens.
16
6.	MILITARY DUTY
MILITARY
DUTY
6
17
Taxpayers
The military duty is paid by residents and non-residents.
Rate
The military duty has been made effective in Ukraine for two years now and
in 2016 it amounts to 1.5%.
Tax base
The military duty is paid from wages, other incentive and compensation
payments or benefits, which are paid to the taxpayer on the basis of his/her
employment relations or civil agreements. These include:
Residents Non-residents
Overall monthly
(annual) taxable
income
Income from
Ukrainian
sources of origin
taxable at the
time of its accrual
(payments,
compensation)
Income from
foreign sources
of origin
Overall monthly
(annual) taxable
income from
Ukrainian
sources of origin
Income from
Ukrainian
sources of origin
taxable at the
time of its accrual
(payments,
compensation)
7.	 EXCISE TAX
EXCISE TAX
7
18
Taxpayers
Excise tax is paid by individuals and legal entities, which:
•	manufacture excise goods on the customs territory of Ukraine, includ-
ing from tolling raw materials;
•	 import excise goods to the customs territory of Ukraine;
•	 distribute excise goods or transfer them into ownership or use.
Rate
Excise tax rates are specified in the Tax Code of Ukraine for each type of
excise goods.
Tax base
The excise tax is levied upon excise goods, which include:
•	 ethyl alcohol and other distillates, alcoholic drinks, beer;
•	 tobacco products, tobacco and manufactured tobacco substitutes;
•	 fuel;
•	cars, trailers and semi-trailers, body thereto, trailers, motorcycles, vehi-
cles for transportation of 10 persons or more, vehicles for transporta-
tion of goods;
•	electricity, except for the distribution of electricity generated by quali-
fied cogeneration units and / or renewable energy sources.
REAL
ESTATE TAX
8
Buildings
Taxpayers
The real estate tax is paid by individuals and legal entities, including
non-residents.
Rate
The amount of real estate tax on buildings is determined by the municipal
authorities. However, the tax rate shall not exceed 3% of the minimal wage
per 1 sq. m. of residential and non-residential property.
The additional tax rate in the amount of UAH 25,000 is applied for apart-
ments of more than 300 square meters and houses of more than 500
square meters.
Tax base
The real estate tax is paid per each sq. m. of residential and non-residential
property. Owners of apartments of less than 60 sq. m. and houses less than
120 sq. m. (or houses and apartments with a total area of 180 sq. m.) are
exempt from tax.
Land plots
Taxpayers
The real estate tax on land plots is paid by individuals and legal entities, in-
cluding non-residents, which own or use such land plots.
Rate
The amount of real estate tax on land plots is determined by the municipal
authorities. The rate shall not exceed 3% of the normative evaluation of a
land plot and 1% for agricultural land plots of general use. For land plots,
which are under permanent use by business entities, the rate shall not ex-
ceed 12% of the normative evaluation.
Tax base
The tax base is land plots in ownership or use.
208.	REAL ESTATE TAX
9.	TRANSPORT TAX
TRANSPORT
TAX
9
21
Taxpayers
The transport tax is paid by individuals and legal entities, including non-
residents, who own vehicles that are registered in Ukraine.
Rate
The rate of transport tax is established in the amount of UAH 25,000 per
year per each vehicle.
Tax base
The transport tax is paid per each vehicle, which has been used for up to
five years from the date of its manufacture with the average market price of
more than 750 minimal wages.
10. ENVIRONMENTAL TAX
ENVIRONMENTAL
TAX
10
22
Taxpayers
The environmental tax is paid by individuals and legal entities, which carry
out their activities on the territory of Ukraine.
Rate
Rates of environmental tax are provided in the Tax Code of Ukraine for
each type of substances.
Tax base
The environmental tax is based on the amount and type of polluted
substances that are released into the air or water objects in Ukraine during
operational activities of legal entities.
11. RENT PAYMENTS
RENT
PAYMENTS
11
23
Taxpayers
Rent payments are paid by individuals and legal entities, which conduct
certain activities on the territory of Ukraine.
Rate
The amount of rent payments is specified in the Tax Code of Ukraine for
each type of resource and its use.
Tax base
Rent payments are required for:
•	 the use of subsoil;
•	 the use of subsoil for the purposes not connected with mining;
•	 the use of radiofrequency in Ukraine;
•	 the special use of water;
•	 the special use of forest resources;
•	transportation of oil and oil products via trunk lines and oil pipelines,
transit pipeline transportation of ammonia on the territory of Ukraine.
12. DUTIES
DUTIES
12
24
In addition to the abovementioned taxes, the Tax Code of Ukraine provides
for the following duties to be applied in Ukraine:
customs duty, which includes:
•	 import duty;
•	 export duty;
•	 seasonal duty;
•	 specific kinds of duty: special, anti-dumping, countervailing;
tourist duty;
vehicle parking place duty.
We also note that further to duties provided in the Tax Code of Ukraine, the
state duty is charged in case of certain actions to be performed by the state
authorities and their officials, such as for acts of public notary offices, public
registration of civil acts, submission of legal claims, etc.
SCHEDULES
SCHEDULE 1 26
Country Date of agreement Effective date Dividends (%) Interest (%)
Royalty
(literary/industrial,%)
Algeria 14.12.2002 01.07.2004 5*/15 10 10/10
Armenia 14.05.1996 19.11.1996 5*/15 10 0/0
Austria 16.10.1997 20.05.1999 5*/10 2/5 5/0
Azerbaijan 30.07.1999 03.07.2000 10 10 10/10
Belarus 24.12.1993 30.01.1995 15 10 15/15
Belgium 20.05.1996 25.02.1999 5*/15 2/5 5/0
Brazil 16.01.2002 26.04.2006 10*/15 15 15/15
Bulgaria 20.11.1995 03.10.1997 5*/15 10 10/10
Canada 04.03.1996 22.08.1996 5*/15 10 0(10)/10
China 04.12.1995 18.10.1996 5*/10 10 10/10
Croatia 10.09.1996 01.06.1999 5*/10 10 10/10
Cyprus 08.11.2012 01.01.2014 5*/15 2 10/5
Cuba 27.03.2003 20.11.2003 5/15 10 0/5
Czech Republic 30.06.1997 20.04.1999 5*/15 5 10/10
Denmark 05.03.1996 21.08.1996 5*/15 10 10/10
Egypt 29.03.1997 27.02.2002 12 12 12/12
Estonia 10.05.1996 24.12.1996 5*/15 10 10/10
Finland 14.10.1994 14.02.1998 5*/15 5/10 10/5
France 30.01.1997 01.11.1999 5*/15 2/10 10/0
Georgia 14.02.1997 01.04.1999 5*/10 10 10/10
Germany 03.07.1995 04.10.1996 5*/10 2/5 5/0
Greece 06.11.2000 26.09.2003 5*/10 10 10/10
Hungary 19.05.1995 24.06.1996 5*/15 10 5/5
Iceland 08.11.2006 09.10.2008 5*/15 10 10/10
LIST OF DOUBLE TAXATION AGREEMENTS OF UKRAINE
SCHEDULE 1 27
India 07.04.1999 31.10.2001 10*/15 10 10/10
Indonesia 11.04.1996 09.11.1998 10*/15 10 10/10
Iran 22.05.1996 21.07.2001 10 10 10/10
Ireland 19.04.2013 17.08.2015 5*/15 5/10 5/10
Israel 26.11.2003 20.04.2006 5*/10*/15 5/10 10/10
Italy 26.02.1997 25.02.2003 5*/15 10 7/7
Japan 18.01.1986 27.11.1986 15 10 0/10
Jordan 30.11.2005 23.10.2008 10*/15 10 10/10
Kazakhstan 09.07.1996 14.04.1997 5*/15 10 10/10
Korea 29.09.1999 19.03.2002 5*/15 5 5/5
Kuwait 20.01.2003 22.02.2004 5 0 10/10
Kyrgyzstan 16.10.1997 01.05.1999 5*/15 10 10/10
Latvia 21.11.1995 21.11.1996 5*/15 10 10/10
Libya 04.11.2008 31.01.2010 5*/15 10 10/10
Lebanon 22.04.2002 06.09.2003 5*/15 10 10/10
Lithuania 23.09.1996 25.12.1997 5*/15 10 10/10
Macedonia 02.03.1998 23.11.1998 5*/15 10 10/10
Malaysia 31.07.1987 01.07.1988 15 15 15/10
Mexico 23.01.2012 01.01.2013 5*/15 10 10/10
Moldova 29.08.1995 27.05.1996 5*/15 10 10/10
Mongolia 01.07.2002 03.11.2006 10 10 10/10
Morocco 13.07.2007 30.03.2009 10 10 10/10
Netherlands 24.10.1995 02.11.1996 5*/15 2/10 10/0
Norway 07.03.1996 18.09.1996 5*/15 10 10/5
Pakistan 23.12.2008 30.06.2011 10*/15 10 10/10
Country Date of agreement Effective date Dividends (%) Interest (%)
Royalty
(literary/industrial,%)
SCHEDULE 1 28
* reduced rate is applicable to qualified ownership rights in a Ukrainian company by a foreign shareholder
Country Date of agreement Effective date Dividends (%) Interest (%)
Royalty
(literary/industrial,%)
Poland 12.01.1993 11.03.1994 5*/15 10 10/10
Portugal 09.02.2000 11.03.2002 10*/15 10 10/10
Republic of South Africa 28.08.2003 23.12.2004 5*/15 10 10/10
Romania 29.03.1996 17.11.1997 10*/15 10 15/10
Russia 08.02.1995 03.08.1999 5/15 10 10/10
Saudi Arabia 02.09.2011 01.12.2012 5*/15 10 10/10
Singapore 26.01.2007 18.12.2009 5*/15 10 7.5/7.5
Slovakia 23.01.1996 22.11.1996 10 10 10/10
Slovenia 23.04.2003 25.04.2007 5*/15 5 10/5
Spain 01.03.1985 07.08.1986 18 0 0/5
Sweden 15.08.1995 04.06.1996 5*/10 10 10/10
Switzerland 30.10.2000 26.02.2002 5*/15 10 10/0
Syria 05.06.2003 04.05.2004 10 10 18/18
Tajikistan 07.09.2002 01.06.2003 10 10 10/10
Thailand 10.03.2004 24.11.2004 10*/15 10/15 15/15
Turkey 27.11.1996 29.04.1998 10*/15 10 10/10
Turkmenistan 29.01.1998 21.10.1999 10 10 10/10
United Arab Emirates 22.01.2003 09.03.2004 5* 3 10/0
United Kingdom 10.02.1993 11.08.1993 5*/10 0 0/0
USA 04.03.1994 05.06.2000 5*/15 0 10/10
Uzbekistan 10.11.1994 25.07.1995 10 10 10/10
Vietnam 08.04.1996 19.11.1996 10 10 10/10
Yugoslavia (Serbia and
Montenegro)
22.03.2001 29.11.2001 5*/10 10 10/10
SCHEDULE 2 29
LIST OF OFFSHORE JURISDICTIONS
Guernsey Isle of Man Jersey Island of Alderney Bahrain Belize
Andorra Gibraltar Monaco Anguilla Antigua and Barbuda Aruba
Bahamas Barbados Bermuda British Virgin Islands Virgin Islands (US) Grenada
Cayman Islands Montserrat Netherlands Antilles Puerto Rico
Saint Vincent and the
Grenadines
Saint Kitts and Nevis
St Lucia
Commonwealth
of Dominica
Turks and Caicos Liberia Seychelles Vanuatu
Marshall Islands Nauru Niue Cook Islands Samoa Maldives
info@dlf.ua
www.dlf.ua
Tel.: +380 44 384 24 54
CONTACTS
DLF attorneys-at-law
Torus Business Centre
17 d Hlybochytska Street
04050 Kyiv, Ukraine

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Taxes in Ukraine | Doing business in Ukraine

  • 2. 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 3 8 11 14 16 17 18 19 21 22 23 24 26 29 Schedule 1. Schedule 2. Corporate income tax Value-added tax Simplified tax system Personal income tax Single social contribution Military duty Excise tax Real estate tax Transport tax Environmental tax Rent payments Duties List of double taxation agreements of Ukraine List of offshore jurisdictions TABLE OF CONTENTS
  • 4. 1. CORPORATE INCOME TAX 4 Taxpayers Corporate Income Tax (CIT) is paid by the resident companies, which receive income in Ukraine as well as abroad. CIT is also paid by the non-resident companies, which receive income from Ukrainian sources. Rate Currently, a flat rate of 18% is established for all CIT taxpayers. However, for some activities a separate rate is applicable. These include: • 3% rate for insurance activities regarding the non-life insurance; • 0% rate for insurance activities regarding the long-term life insurance, voluntary medical insurance and non-state pension schemes; • 10% rate for lotteries and gambling activities using gaming machines; • 0%, 4% and 12% for non-resident insurers based on insurance agreement (depending on the insurance accident case); • 6% for a freight amount paid by a resident to a non-resident under freight contracts; • 15% for residents or permanent representative offices in Ukraine, which make payments to non-residents from the income derived from Ukrainian sources of origin; • 20% for residents, which make payments to non-residents for advertising production or its distribution. Tax base The CIT base is the income derived from Ukrainian sources of origin and abroad. The amount of tax is determined by adjustment of financial result (profit or loss) before tax, as calculated in accordance with the Ukrainian accounting standards or IFRS. Peculiarities of taxation Adjustment of financial results Adjustment of financial results is possible by way of: 1) Amortization The financial result before tax is increased by: • the amount of the accrued depreciation of fixed assets or intangible assets pursuant to the Ukrainian accounting standards or IFRS; • the amount of write-off and impairment of fixed assets and intangible assets, included in the expenses of the reporting period in accordance with the Ukrainian accounting standards or IFRS; • the amount of residual value of a separate item of fixed assets or intangible assets defined by the Ukrainian accounting standards or IFRS, in the event of liquidation or sale of such asset.
  • 5. 1. CORPORATE INCOME TAX 5 The financial result before tax is decreased by: • the amount of the depreciation of fixed assets and intangible assets; • the amount of residual value of a separate item of fixed assets or intan- gible assets, defined by tax accounting in the event of liquidation or sale of such asset; • the amount of revaluations and gains from the recovery of fixed assets and intangible assets value in the amount of losses from the previous period write-off and impairment of such assets in accordance with the Ukrainian accounting standards or IFRS. 2) Reimbursement for future expenses The financial result before tax is increased by: • the amount of expenses on accrued provisions for future expenses and payments in accordance with the Ukrainian accounting standards or IFRS. The financial result before tax is decreased by: • the amount of realization of accrued provisions or future expenses and payments, accrued in accordance with the Ukrainian accounting stand- ards of IFRS; • the amount of provision reduction if it has increased the financial profit (loss) before tax. 3) Doubtful debts The financial result before tax is increased by: • the amount of doubtful debts accrued in accordance with the Ukrainian accounting standards or IFRS; • the amount of receivables write-off that does not fulfil the criteria of bad debt over debts allowance. The financial result before tax is decreased by: • the amount of doubtful debts allowance reduction if it has increased the financial result before tax in accordance with the Ukrainian account- ing standards or IFRS. Some types of profit are not included in the overall taxable income. These include: • the income from the interest accrued on securities of the Ministry of Finance of Ukraine and the NBU’s debt obligations; • the income received by non-residents as the interest accrued on gov- ernment securities or municipal bonds or debt securities guaranteed by the state; • the body of the deposit at a bank or non-bank financial institution; • the principal amount of repayable returnable financial aid provided by a taxpayer to other persons. The principal amount of repayable financial aid received by a taxpayer;
  • 6. • the investment profit from transactions with debt obligations of the NBU and treasury obligations of Ukraine; • the income from international financial organizations under the frame- work of implementation of energy efficiency and energy saving projects. Taxation of non-residents The income of non-resident legal entities derived from Ukrainian sources of origin is taxed by CIT at the rate of 15%. The CIT tax base is the income from dividends, royalties, freight, the proceeds of engineering, leasing and rent, profits from sale of real estate, securities and corporate rights, the proceeds of joint activities and entertainment activities, etc. In relation to the income from Ukrainian sources of origin, the following rates apply: In certain cases, the lower tax rate might apply under the double taxation agreements. Ukraine has valid double taxation agreements with approxi- mately 75 countries (see Schedule 1). It should also be noted that double taxation agreements with specific countries may provide for more favour­ able taxation arrangements. Transfer pricing For the purposes of correct CIT taxation, the control has been established over related-party transactions. In addition, such control is exercised over transactions with non-residents in low-tax jurisdictions. The list of such countries is specified by the Cabinet of Ministers of Ukraine and provided in Schedule 2. Low-tax jurisdictions are determined on the basis of the following criteria: • the general CIT rate in such countries is by 5 or more percentage points lower than in Ukraine; • Ukraine does not have any agreements on information exchange with such countries. The transfer pricing control is exercised over transactions, where: • the taxpayer’s revenue exceeds UAH 50 million* for the tax year; • the annual volume of the transactions with one counterparty (related person) exceeds UAH 5 million. 1. CORPORATE INCOME TAX 6 Dividends 15% Interest 15% Royalty 15% Freight 6% Other profits from Ukrainian sources of origin 15% * As of 30 June 2016 the National Bank of Ukraine established its official currency exchange rate at UAH 24.85 per one US dollar.
  • 7. Fines for failure to submit a report on the controlled transactions and re- spective documentation on transfer pricing are as follows: • 300 minimal wages* for failure to submit the report on controlled trans- actions; • 1% of the amount of transactions omitted from the report, but no more than 300 minimal wages for all undeclared transactions; • 3% of the amount of transactions in respect of which transfer pricing documentation was not submitted, but no more than 200 minimal wages. Thin capitalization rules In order to prevent tax base erosion and profit outflow from the country, there are the thin capitalization rules effective in Ukraine. Under the thin capitalization rules, expenses of the resident in the current tax period include the amount of interest paid on loans, which does not exceed 50% of profits, expenses on repayment of interests. It should be noted that a non-resident is deemed to be a related party if the amount of taxpayer’s liabili- ties with such non-resident exceeds the equity ratio by more than 3.5 times. 1. CORPORATE INCOME TAX 7 * Currently, one minimal wage in Ukraine amounts to UAH 1,450. Starting from 01 December 2016 the minimal wage will amount to UAH 1,550. The minimal wage is specified each year in the state budged of Ukraine.
  • 9. 2. VALUE-ADDED TAX 9 Taxpayers The taxpayer is obliged to register as a VAT payer if the aggregate value of supplied goods or services exceeds UAH 1 million for the last 12 months. However, if the value of taxable transactions does not exceed UAH 1 million, the voluntary registration as a VAT payer is available. Rate The VAT rate is 20%. For pharmaceutical products, the VAT rate is 7%. It should be noted that 0% VAT rate is applied to export of goods in the cus- toms regime from the territory of Ukraine. Tax base VAT is applied to transactions on supply of goods and services on the cus- tom territory of Ukraine, as well as to transactions related to import and export of goods in Ukraine. In addition, services on international transporta- tion of passengers and luggage by sea, river and air transport are also sub- ject to VAT. The following transactions are not subject to VAT: • issue of securities by business entities; • provision of insurance services by the licensed organizations; • provision of services of payment systems related to transfer of funds, encashment, cash management services, attraction, placement and refund under loans, deposit and securities management agreements, management and assignment of claims to financial institutions; • payment of salary in cash; • provision of educational services; • provision of administrative services; • provision of banking services; • import and export of goods to the amount less than EUR 150; • payment under lease or concession agreements; • reorganization (merger, accession, division, separation and transforma- tion) of legal entities. Peculiarities of taxation VAT refund Following cancellation of automatic VAT refund in 2016, there are two regis- ters of budget VAT refund.
  • 10. are not subject to insolvency procedures. are listed in the Unified State Register of Legal Entities and Individual Entrepreneurs with their profile containing no data on: • failure to provide confirmation of submitted data; • failure to establish presence at the registered office location; • adoption of resolution in relation to separation or termination of a legal entity; • declaring constitutional documents or changes to constitutional documents of a legal entity as fully or partially null and void; • termination of the state registration of a legal entity or individual entrepreneur. have fixed assets with the residual book value exceeding the amount of tax claimed for refund by more than three times; or received a financial guarantee for up to one year from the banking institution; or perform transactions on export of goods from the customs territory of Ukraine under the customs regime, whose share in the previous reporting 12 consecutive tax periods (months) together is at least 40 percent of total shipments. The second register is aimed at taxpayers who do not meet the abovemen- tioned requirements. Special regime for agricultural producers Special taxation regime for agricultural producers is valid until 1 January 2017. Such regime provides that: • under transactions with agricultural goods/services (except for grain and industrial crops, as well as livestock transactions), 50% of VAT shall be paid to the state budget and 50% of VAT shall be credited to the spe- cial VAT account of the agricultural producer; • under transactions with grain and industrial crops, 85% of VAT shall be paid to the state budget and 15% of VAT shall be credited to the special VAT account of the agricultural producer; • under transactions with livestock, 20% of VAT shall be paid to the state budget and 80% of VAT shall be credited to the special VAT account of the agricultural producer. 2. VALUE-ADDED TAX 10 The first is for the taxpayers, which meet the following criteria:
  • 12. 3. SIMPLIFIED TAX SYSTEM 12 І group IІ group ІII group ІV group Taxpayer Number of employees Max. profit per year Tax rate Type of activities Private entrepreneur Retail sale of goods at market places, provision of consumer services to citizens Provision of services (including consumer services) to the single tax payers and citizens; manufacturing and sale of goods; restaurant activities, etc. All types of business activities permitted under single tax rules Agriculture producers with the share of agricultural commodity production in the previous tax year at least 75% Private entrepreneur Private entrepreneur / legal entity Private entrepreneur / legal entity 0 UAH 300,000 Up to 10% of minimal wage Up to 10 UAH 1.5 million Up to 20% of minimal wage No restrictions UAH 5 million 3% of income (VAT excluded); 5% of income (VAT included) No restrictions — Depending on the category of land, its location and amounts (in per cent of the tax base): • for arable land, hayfields and pastures — 0.81; • for arable land, hayfields and pastures located in mountainous areas and marshy woodland areas — 0.49; • for perennial plantations — 0.49; • for perennial plantations located in mountainous areas and marshy woodland areas — 0.16; • for lands of water fund — 2.43; • for arable land, hayfields and pastures on closed soil — 5.4. With the aim of facilitation and easement of small and medium business accounting, Ukraine introduced special taxation terms for such businesses. The taxpayers, both private entrepreneurs and legal entities, may choose to apply for a simplified taxation system in one of the following categories:
  • 13. 3. SIMPLIFIED TAX SYSTEM 13 Peculiarities of taxation Agricultural producers Legal persons have the right to choose the fourth group of the single tax provided that their share of agricultural commodity production in the previ- ous year amounted to at least 75%. This is applicable to: • all entities separately, which carry out merger or accession. In this case, it is possible to become a single tax payer in the year of creation, if the share of agricultural commodity production for the previous tax year by all com- modity producers involved in their creation equals to or exceeds 75%; • each individual entity created by split-up or spin-off. In this case, it is possible to become a single tax payer from the next year, if the share of agricultural commodity production for the previous tax year equals to or exceeds 75%; • an entity created by transformation. In this case, it is possible to be- come a single tax payer in the year of transformation, if the share of agricultural commodity obtained for the previous tax year equals to or exceeds 75%. Newly created agricultural commodity producers may be single tax payers from the next year, if share of agricultural commodity production obtained for the previous tax year equals to or exceeds 75%.
  • 15. Taxpayers The personal income tax (PIT) is paid by resident and non-resident individu- als. Rate PIT rate is 18%, while PIT rate for dividend payments is 5%. Tax base The monthly (annual) taxable income of taxpayer does not include: • the interest accrued on certain state securities issued by the NBU; • the alimony received in accordance with the court ruling or voluntary ar- rangement of the parties as provided by the Family Code of Ukraine; • body of the deposit at a bank or non-bank financial institution; • the income of private entrepreneur, which is subject to single tax; • insurance payments, pension payments, etc., received under the long- term life insurance agreement; • amounts forgiven (annulled) by the lender; • the income from financial (including international) organizations under the framework of implementation of energy efficiency and energy sav- ing projects; • the amount of property and non-property contribution to the charter capital of a legal entity; • the charity aid amounts. 4. PERSONAL INCOME TAX 15 Residents Non-residents Monthly (annual) taxable income Income from Ukrainian sources of origin, taxable at the time of its accrual (payments, compensation) Income from foreign sources of origin Monthly (annual) taxable income from Ukrainian sources of origin Income from Ukrainian sources of origin, taxable at the time of its accrual (payments, compensation)
  • 16. 5. SINGLE SOCIAL CONTRIBUTION SINGLE SOCIAL CONTRIBUTION 5 Rate The single social contribution rate is established at 22%. However, the maximum taxable amount of the single social contribution shall not exceed 25 minimal wages. Tax base The single social contribution is paid from wages and bonuses of employees as well as income of private entrepreneurs. Taxpayers The single social contribution is paid by the employers, private entrepreneurs, self-employed citizens. 16
  • 17. 6. MILITARY DUTY MILITARY DUTY 6 17 Taxpayers The military duty is paid by residents and non-residents. Rate The military duty has been made effective in Ukraine for two years now and in 2016 it amounts to 1.5%. Tax base The military duty is paid from wages, other incentive and compensation payments or benefits, which are paid to the taxpayer on the basis of his/her employment relations or civil agreements. These include: Residents Non-residents Overall monthly (annual) taxable income Income from Ukrainian sources of origin taxable at the time of its accrual (payments, compensation) Income from foreign sources of origin Overall monthly (annual) taxable income from Ukrainian sources of origin Income from Ukrainian sources of origin taxable at the time of its accrual (payments, compensation)
  • 18. 7. EXCISE TAX EXCISE TAX 7 18 Taxpayers Excise tax is paid by individuals and legal entities, which: • manufacture excise goods on the customs territory of Ukraine, includ- ing from tolling raw materials; • import excise goods to the customs territory of Ukraine; • distribute excise goods or transfer them into ownership or use. Rate Excise tax rates are specified in the Tax Code of Ukraine for each type of excise goods. Tax base The excise tax is levied upon excise goods, which include: • ethyl alcohol and other distillates, alcoholic drinks, beer; • tobacco products, tobacco and manufactured tobacco substitutes; • fuel; • cars, trailers and semi-trailers, body thereto, trailers, motorcycles, vehi- cles for transportation of 10 persons or more, vehicles for transporta- tion of goods; • electricity, except for the distribution of electricity generated by quali- fied cogeneration units and / or renewable energy sources.
  • 20. Buildings Taxpayers The real estate tax is paid by individuals and legal entities, including non-residents. Rate The amount of real estate tax on buildings is determined by the municipal authorities. However, the tax rate shall not exceed 3% of the minimal wage per 1 sq. m. of residential and non-residential property. The additional tax rate in the amount of UAH 25,000 is applied for apart- ments of more than 300 square meters and houses of more than 500 square meters. Tax base The real estate tax is paid per each sq. m. of residential and non-residential property. Owners of apartments of less than 60 sq. m. and houses less than 120 sq. m. (or houses and apartments with a total area of 180 sq. m.) are exempt from tax. Land plots Taxpayers The real estate tax on land plots is paid by individuals and legal entities, in- cluding non-residents, which own or use such land plots. Rate The amount of real estate tax on land plots is determined by the municipal authorities. The rate shall not exceed 3% of the normative evaluation of a land plot and 1% for agricultural land plots of general use. For land plots, which are under permanent use by business entities, the rate shall not ex- ceed 12% of the normative evaluation. Tax base The tax base is land plots in ownership or use. 208. REAL ESTATE TAX
  • 21. 9. TRANSPORT TAX TRANSPORT TAX 9 21 Taxpayers The transport tax is paid by individuals and legal entities, including non- residents, who own vehicles that are registered in Ukraine. Rate The rate of transport tax is established in the amount of UAH 25,000 per year per each vehicle. Tax base The transport tax is paid per each vehicle, which has been used for up to five years from the date of its manufacture with the average market price of more than 750 minimal wages.
  • 22. 10. ENVIRONMENTAL TAX ENVIRONMENTAL TAX 10 22 Taxpayers The environmental tax is paid by individuals and legal entities, which carry out their activities on the territory of Ukraine. Rate Rates of environmental tax are provided in the Tax Code of Ukraine for each type of substances. Tax base The environmental tax is based on the amount and type of polluted substances that are released into the air or water objects in Ukraine during operational activities of legal entities.
  • 23. 11. RENT PAYMENTS RENT PAYMENTS 11 23 Taxpayers Rent payments are paid by individuals and legal entities, which conduct certain activities on the territory of Ukraine. Rate The amount of rent payments is specified in the Tax Code of Ukraine for each type of resource and its use. Tax base Rent payments are required for: • the use of subsoil; • the use of subsoil for the purposes not connected with mining; • the use of radiofrequency in Ukraine; • the special use of water; • the special use of forest resources; • transportation of oil and oil products via trunk lines and oil pipelines, transit pipeline transportation of ammonia on the territory of Ukraine.
  • 24. 12. DUTIES DUTIES 12 24 In addition to the abovementioned taxes, the Tax Code of Ukraine provides for the following duties to be applied in Ukraine: customs duty, which includes: • import duty; • export duty; • seasonal duty; • specific kinds of duty: special, anti-dumping, countervailing; tourist duty; vehicle parking place duty. We also note that further to duties provided in the Tax Code of Ukraine, the state duty is charged in case of certain actions to be performed by the state authorities and their officials, such as for acts of public notary offices, public registration of civil acts, submission of legal claims, etc.
  • 26. SCHEDULE 1 26 Country Date of agreement Effective date Dividends (%) Interest (%) Royalty (literary/industrial,%) Algeria 14.12.2002 01.07.2004 5*/15 10 10/10 Armenia 14.05.1996 19.11.1996 5*/15 10 0/0 Austria 16.10.1997 20.05.1999 5*/10 2/5 5/0 Azerbaijan 30.07.1999 03.07.2000 10 10 10/10 Belarus 24.12.1993 30.01.1995 15 10 15/15 Belgium 20.05.1996 25.02.1999 5*/15 2/5 5/0 Brazil 16.01.2002 26.04.2006 10*/15 15 15/15 Bulgaria 20.11.1995 03.10.1997 5*/15 10 10/10 Canada 04.03.1996 22.08.1996 5*/15 10 0(10)/10 China 04.12.1995 18.10.1996 5*/10 10 10/10 Croatia 10.09.1996 01.06.1999 5*/10 10 10/10 Cyprus 08.11.2012 01.01.2014 5*/15 2 10/5 Cuba 27.03.2003 20.11.2003 5/15 10 0/5 Czech Republic 30.06.1997 20.04.1999 5*/15 5 10/10 Denmark 05.03.1996 21.08.1996 5*/15 10 10/10 Egypt 29.03.1997 27.02.2002 12 12 12/12 Estonia 10.05.1996 24.12.1996 5*/15 10 10/10 Finland 14.10.1994 14.02.1998 5*/15 5/10 10/5 France 30.01.1997 01.11.1999 5*/15 2/10 10/0 Georgia 14.02.1997 01.04.1999 5*/10 10 10/10 Germany 03.07.1995 04.10.1996 5*/10 2/5 5/0 Greece 06.11.2000 26.09.2003 5*/10 10 10/10 Hungary 19.05.1995 24.06.1996 5*/15 10 5/5 Iceland 08.11.2006 09.10.2008 5*/15 10 10/10 LIST OF DOUBLE TAXATION AGREEMENTS OF UKRAINE
  • 27. SCHEDULE 1 27 India 07.04.1999 31.10.2001 10*/15 10 10/10 Indonesia 11.04.1996 09.11.1998 10*/15 10 10/10 Iran 22.05.1996 21.07.2001 10 10 10/10 Ireland 19.04.2013 17.08.2015 5*/15 5/10 5/10 Israel 26.11.2003 20.04.2006 5*/10*/15 5/10 10/10 Italy 26.02.1997 25.02.2003 5*/15 10 7/7 Japan 18.01.1986 27.11.1986 15 10 0/10 Jordan 30.11.2005 23.10.2008 10*/15 10 10/10 Kazakhstan 09.07.1996 14.04.1997 5*/15 10 10/10 Korea 29.09.1999 19.03.2002 5*/15 5 5/5 Kuwait 20.01.2003 22.02.2004 5 0 10/10 Kyrgyzstan 16.10.1997 01.05.1999 5*/15 10 10/10 Latvia 21.11.1995 21.11.1996 5*/15 10 10/10 Libya 04.11.2008 31.01.2010 5*/15 10 10/10 Lebanon 22.04.2002 06.09.2003 5*/15 10 10/10 Lithuania 23.09.1996 25.12.1997 5*/15 10 10/10 Macedonia 02.03.1998 23.11.1998 5*/15 10 10/10 Malaysia 31.07.1987 01.07.1988 15 15 15/10 Mexico 23.01.2012 01.01.2013 5*/15 10 10/10 Moldova 29.08.1995 27.05.1996 5*/15 10 10/10 Mongolia 01.07.2002 03.11.2006 10 10 10/10 Morocco 13.07.2007 30.03.2009 10 10 10/10 Netherlands 24.10.1995 02.11.1996 5*/15 2/10 10/0 Norway 07.03.1996 18.09.1996 5*/15 10 10/5 Pakistan 23.12.2008 30.06.2011 10*/15 10 10/10 Country Date of agreement Effective date Dividends (%) Interest (%) Royalty (literary/industrial,%)
  • 28. SCHEDULE 1 28 * reduced rate is applicable to qualified ownership rights in a Ukrainian company by a foreign shareholder Country Date of agreement Effective date Dividends (%) Interest (%) Royalty (literary/industrial,%) Poland 12.01.1993 11.03.1994 5*/15 10 10/10 Portugal 09.02.2000 11.03.2002 10*/15 10 10/10 Republic of South Africa 28.08.2003 23.12.2004 5*/15 10 10/10 Romania 29.03.1996 17.11.1997 10*/15 10 15/10 Russia 08.02.1995 03.08.1999 5/15 10 10/10 Saudi Arabia 02.09.2011 01.12.2012 5*/15 10 10/10 Singapore 26.01.2007 18.12.2009 5*/15 10 7.5/7.5 Slovakia 23.01.1996 22.11.1996 10 10 10/10 Slovenia 23.04.2003 25.04.2007 5*/15 5 10/5 Spain 01.03.1985 07.08.1986 18 0 0/5 Sweden 15.08.1995 04.06.1996 5*/10 10 10/10 Switzerland 30.10.2000 26.02.2002 5*/15 10 10/0 Syria 05.06.2003 04.05.2004 10 10 18/18 Tajikistan 07.09.2002 01.06.2003 10 10 10/10 Thailand 10.03.2004 24.11.2004 10*/15 10/15 15/15 Turkey 27.11.1996 29.04.1998 10*/15 10 10/10 Turkmenistan 29.01.1998 21.10.1999 10 10 10/10 United Arab Emirates 22.01.2003 09.03.2004 5* 3 10/0 United Kingdom 10.02.1993 11.08.1993 5*/10 0 0/0 USA 04.03.1994 05.06.2000 5*/15 0 10/10 Uzbekistan 10.11.1994 25.07.1995 10 10 10/10 Vietnam 08.04.1996 19.11.1996 10 10 10/10 Yugoslavia (Serbia and Montenegro) 22.03.2001 29.11.2001 5*/10 10 10/10
  • 29. SCHEDULE 2 29 LIST OF OFFSHORE JURISDICTIONS Guernsey Isle of Man Jersey Island of Alderney Bahrain Belize Andorra Gibraltar Monaco Anguilla Antigua and Barbuda Aruba Bahamas Barbados Bermuda British Virgin Islands Virgin Islands (US) Grenada Cayman Islands Montserrat Netherlands Antilles Puerto Rico Saint Vincent and the Grenadines Saint Kitts and Nevis St Lucia Commonwealth of Dominica Turks and Caicos Liberia Seychelles Vanuatu Marshall Islands Nauru Niue Cook Islands Samoa Maldives
  • 30. info@dlf.ua www.dlf.ua Tel.: +380 44 384 24 54 CONTACTS DLF attorneys-at-law Torus Business Centre 17 d Hlybochytska Street 04050 Kyiv, Ukraine