DOCSLIB.ORG

Ukraine a Follow-Up on Distributed Profit Tax, BEPS Implementation, Voluntary Disclosure Program, and Indirect Methods for Determining Taxable Income

Total Page：16

File Type：pdf, Size：1020Kb

Download full-text PDF Read full-text
Ukraine a Follow-Up on Distributed Profit Tax, BEPS Implementation, Voluntary Disclosure Program, and Indirect Methods for Determining Taxable Income IMF Country Report No. 20/302 UKRAINE TECHNICAL ASSISTANCE REPORT––A FOLLOW-UP ON November 2020 DISTRIBUTED PROFIT TAX, BEPS IMPLEMENTATION, VOLUNTARY DISCLOSURE PROGRAM, AND INDIRECT METHODS FOR DETERMINING TAXABLE INCOME This Technical Assistance Report paper on Ukraine was prepared by a staff team of the International Monetary Fund. It is based on the information available at the time it was completed on September 2020. Copies of this report are available to the public from International Monetary Fund • Publication Services PO Box 92780 • Washington, D.C. 20090 Telephone: (202) 623-7430 • Fax: (202) 623-7201 E-mail: [email protected] Web: http://www.imf.org Price: $18.00 per printed copy International Monetary Fund Washington, D.C. © 2020 International Monetary Fund ©International Monetary Fund. Not for Redistribution FISCAL AFFAIRS DEPARTMENT Ukraine A Follow-Up on Distributed Profit Tax, BEPS Implementation, Voluntary Disclosure Program, and Indirect Methods for Determining Taxable Income Roberto Schatan, Martin Grote, Lee Burns and Oscar Molina Technical Report September 2020 ©International Monetary Fund. Not for Redistribution CONTENTS ABBREVIATIONS AND ACRONYMS _____________________________________________________________ 4 PREFACE __________________________________________________________________________________________5 EXECUTIVE SUMMARY __________________________________________________________________________ 6 I. DISTRIBUTED PROFIT TAX ___________________________________________________________________ 11 A. New Momentum for the Distributed Profit Tax ________________________________________________ 11 B. Compromise Proposals ________________________________________________________________________ 12 II. VOLUNTARY DISCLOSURE PROGRAM ______________________________________________________ 15 A. Previous Advice on Draft VDP Legislation _____________________________________________________ 15 B. Policy Attraction of VDPs and General Amnesties _____________________________________________ 17 C. Further Advice on the Draft VDP for Foreign-Held Assets _____________________________________ 20 D. Draft One-Time Asset Declaration for the “Indirect Method” _________________________________ 29 III. INDIRECT METHODS TO ESTIMATE TAXABLE INCOME ___________________________________ 31 A. Indirect Methods and the Perception of Risk __________________________________________________ 31 B. Implementing the Indirect Methods ___________________________________________________________ 33 C. Elements of an Indirect Method _______________________________________________________________ 34 D. General Operational Aspects of the Indirect Method _________________________________________ 36 E. Administrative Issues __________________________________________________________________________ 37 F. The Voluntary Disclosure Program and the Indirect Method __________________________________ 37 IV. INTERNATIONAL TAX MEASURES __________________________________________________________ 39 A. Introduction ___________________________________________________________________________________ 39 B. Place of Effective Management ________________________________________________________________ 39 C. Permanent Establishment (PE) _________________________________________________________________ 43 D. Controlled Foreign Company Rules ___________________________________________________________ 48 E. Indirect Transfer of Immovable Property ______________________________________________________ 59 V. CHANGES TO TRANSFER PRICING REGULATIONS _________________________________________ 61 A. Special Rules for Transfer Pricing of Commodities ____________________________________________ 62 B. Business Restructuring _________________________________________________________________________ 63 C. Business Purpose Test _________________________________________________________________________ 64 D. Thin Cap _______________________________________________________________________________________ 71 E. Special Rules Defining Related Parties and Thin Cap __________________________________________ 73 BOXES 1. Lessons from the South African Exchange Control Amnesty with Supporting Tax Measures __ 24 2. Aspects of the South African Amnesty Legislation that were Difficult to Implement __________ 27 3. Updating Ownership Registers of Immovable Property in lieu of a VDP Process ______________ 30 4. Legislation on Indirect Methods – the Case of Mexico ________________________________________ 35 2 ©International Monetary Fund. Not for Redistribution 5. A Basic Formula for an Indirect Method including Cash _______________________________________ 36 6. Disallowing the Deduction of Non-Business Expenses ________________________________________ 66 7. Understanding the Business Purpose Test in Transfer Pricing _________________________________ 67 APPENDICES I. Approaches to Develop and Maintain Up-to-Date Property Cadasters ________________________ 74 II. Mexico’s Legislation on Indirect Method ______________________________________________________ 76 3 ©International Monetary Fund. Not for Redistribution ABBREVIATIONS AND ACRONYMS AL Arm’s Length ALP Arm’s Length Principle AEOI Automatic Exchange of Information AML Anti-Money Laundering BEPS Base Erosion and Profit Shifting Work Program Organized by the OECD CbC Country-by-Country CFC Controlled Foreign Corporation CPT Corporate Profit Tax or Corporate Income Tax CUP Comparable Uncontrolled Price CUC Controlled Ukraine Company DPT Distributed Profit Tax EBITDA Earnings before Interest, Tax, Depreciation and Amortization ECT Exit Capital Tax FAD Fiscal Affairs Department of the IMF FATF Financial Action Task Force IFRS International Financial Reporting Standards IMF International Monetary Fund MNE Multinational Enterprise MOF Ministry of Finance NBU National Bank of Ukraine OECD Organization for Economic Cooperation and Development PE Permanent Establishment PEM Place of Effective Management PIT Personal Income Tax STS State Tax Service TP Transfer Pricing UAH Ukrainian Hryvnia UN United Nations UTC Ukrainian Tax Code VDP Voluntary Disclosure Program 4 ©International Monetary Fund. Not for Redistribution PREFACE In response to a request from the Ministry of Finance, a technical assistance mission from the International Monetary Fund’s (IMF) Fiscal Affairs Department (FAD) delivered a remote mission from Washington, DC, initially programmed for June 30 – July 13, and then extended to July 21, 2020, to review selected international tax issues and advise on a Voluntary Disclosure Program and the Exit Capital Tax. The mission comprised Messrs. Roberto Schatan (mission head), Martin Grote (both from FAD) and Mr. Lee Burns and Mr. Oscar Molina (external experts). The mission presented the aide memoire and explained its recommendations to the Minister of Finance, Mr. Sergii Marchenko. During the mission the team had several rounds of productive (remote) discussions with technical staff of the MoF, headed by the Deputy Minister of Finance Ms. Svitlana Vorobey. The technical staff of the MoF included Messrs. Roman Goptsii and Yevhen Kozlov, Mr Kostiantyn Penskoy, senior tax managers in the Reform Support Team (MoF); Ms. Liudmyla Palamar, Head of the International Taxation Division; Victor Orcharenko, Deputy Head of the Tax Policy Department; Mr Andrii Khomutskii – Head of Personal Income Tax Unit; Ms Olena Markevich – Head of Corporate Income Tax Unit; from the STS: Igor Danylov –Tax Administration Department, Tetiana Radchenko, Tax Audit Division; Mr Viacheslav Krugliak – Deputy Head of Transfer Pricing Division. Also, Ms Olena Diachenko – Director of Directorate General on Economic Policy of the Presidential Office; and Mr Oleg Strynzha – Head of Finance Controlling Department of National Bank of Ukraine participated in the meetings. The mission held video conferences with representatives from the private sector, including the European Business Association, the American Chamber of Commerce, KPMG, Deloitte, EY, PwC and Cargill. The team acknowledges the support received from Mr. Ihor Shpak from the IMF Kiev office. Finally, the mission would like to express its appreciation to Ms. Iryna Krupska for her outstanding interpretation work. 5 ©International Monetary Fund. Not for Redistribution EXECUTIVE SUMMARY Tax policy in Ukraine is engaged in two fronts at once. On one front, very significant work has been done over the years on the gradual improvement and updating of the tax system; on the other, it questions essential tenets of the existing system, exploring fundamental changes to it. While serious efforts have been devoted, for example, to the modernization of the international aspects of the income tax, upgrading the regime to OECD standards, there is a strong push from some quarters of the policy debate to do away with the Corporate Profit Tax (CPT) altogether. The central idea is to replace it with a Distributed Profit Tax (DPT), generally referred to in Ukraine as the Exit Capital Tax (ECT). In essence, this system would not tax profits as they accrue to the corporation, deferring the tax to when the corporation distributes dividends to the shareholder. Finding a middle ground does not seem to be a feasible option. In previous reports FAD has argued against the adoption of the ECT: it would lead to a significant loss of revenue, it is fundamentally regressive, it is complex to control, and there is no evidence that it may help growing investment. However, the push to adopt it has not died down, even if adopting it only partially as a
Load more

Recommended publications
  • TAX HANDBOOK 2015 INVESTING in UKRAINE the Purpose of This Handbook Is to Provide Basic Legal Information for Investors Seeking to Conduct Business in Ukraine
    TAX HANDBOOK 2015 INVESTING IN UKRAINE The purpose of this handbook is to provide basic legal information for investors seeking to conduct business in Ukraine. This is a second updated edition of the handbook first published in 2013. The handbook is based on general principles of Ukrainian law and does not represent any kind of legal opinion. Should you require legal advice on a specific issue, please contact Wolf Theiss directly. The contents of this handbook were prepared by Wolf Theiss on the basis of information available and accurate as of June 2015. The reader should note that the information contained herein may change on short notice. Wolf Theiss disclaims any responsibility for the completeness and accuracy of the content of this handbook and for any subsequent changes. This handbook was prepared by Wolf Theiss and is protected by copyright. Material appearing herein may only be reproduced or translated with an appropriate credit. For further information, please contact: WOLF THEISS LLC 5 Spaska Str. UA – 04071 Kyiv T: +380 44 3 777 500 F: +380 44 3 777 501 [email protected] Anna Kvederis Head of Tax Practice at the WOLF THEISS Kyiv Office T: +380 50 440 93 87 [email protected] Taras Dumych Partner T: +380 50 382 91 79 [email protected] Status of information: Current as of June 2015 Conception, design, and editing: WOLF THEISS Rechtsanwälte GmbH, Attorneys-at-Law Schubertring 6, 1010 Vienna, Austria www.wolftheiss.com © 2015 WOLF THEISS Rechtsanwälte GmbH. All Rights Reserved. WHY UKRAINE 4 Major Economic
    [Show full text]
  • TAX CODE of UKRAINE SECTION І. GENERAL PROVISIONS Article 1
    TAX CODE OF UKRAINE SECTION І. GENERAL PROVISIONS Article 1. Application Area of the Tax Code of Ukraine 1.1. The Tax Code of Ukraine governs the relations that arise in the area of charging taxes and duties, for instance, establishes an exhaustive list of taxes and duties charged in Ukraine and the procedure of the administration thereof, the payers of taxes and duties, their rights and responsibilities, the competence of control agencies and the powers and responsibilities of their officials in the course of the exercise of the tax control, as well as the liability for the violations of the tax legislation. 1.2. Rules of taxation of commodities or services that move across the customs border of Ukraine shall be determined by this Code, except for the taxation by means of import tax or export tax, which shall be determined by the Customs Code of Ukraine and other customs laws. 1.3. This Code shall not govern the issues of tax liabilities repayment or collection of the tax debt from the persons, to whom the court procedures apply, which are determined by the Law of Ukraine “On Re-establishing Debtor Solvency or Declaring It Bankrupt”, from the banks, to which the norms of Section V of the Law of Ukraine “On Banks and Banking Activities” apply, and repayment of the unified obligatory national pension insurance fee. Article 2. Amendment of the Tax Code of Ukraine 2.1. Amendment of the provisions of this Code may be effected only by way of the amendment of this Code. Article 3.
    [Show full text]
  • Actual Information
    ACTUAL INFORMATION TAX REFORM 2020 IN UKRAINE – 7. July 2020 OVERVIEW OF CHANGES IN INTERNATIONAL TAXATION On May 23, 2020, the Law of Ukraine No. 466-IX of 16 January 2020 on enhancement of tax administration, removal of technical and logical inconsistencies in tax legislation became effective. This law introduced many changes to the provisions of the Tax Code of Ukraine (Tax Code) related to international taxation. The overview of the key changes is provided below. ACTUAL INFORMATION 7. JULY 2020 1. Changes in Taxation of Transactions with Nonresidents The principal purpose test was introduced as a condition for the application of reduced withholding tax rates and exemptions from tax under double tax treaties. Such benefits will now be available only if obtaining of the treaty benefits was not the principal or one of the principal purposes of the transaction with a nonresident and granting these benefits would be in accordance with the object and purpose of the provisions of the international treaty of Ukraine (Sec. 3 Par. 103.2 of the Tax Code). A “look-through” approach was implemented for the purposes of application of the double tax treaties, if the immediate recipient of Ukrainian-source income is not the beneficial owner of the income. For the application of the treaty with the country of which the beneficial owner is a resident, the recipient of the income and the beneficial owner must file applications and provide documents confirming the status of the beneficial owner (e.g. licenses, agreements, letters of competent authorities) (Sec. 4 Par. 103.2, Sec. 5 Par.
    [Show full text]
  • Client Alert Tax Kyiv | January 2020
    Client alert Tax Kyiv | January 2020 УКРАЇНСЬКА ВЕРСІЯ І FORWARD | WEBSITE Tax Code Overhaul in Ukraine On 16 January 2020, the Parliament of Ukraine finally passed the heatedly debated Law "On Amendments to the Tax Code of Ukraine Purposed to Improve the Administration of Taxes, Eliminate Technical and Logical Inconsistencies in the Tax Legislation" ("Anti-BEPS Law"). The Anti-BEPS Law shall come into force once it is signed into law by the President of Ukraine and officially published. In the meanwhile, on 17 January 2020, a group of parliamentarians moved with the initiative to rescind the results of the vote on the Anti-BEPS Law, blocking thereby the completion of the legislative procedure. Only after the said initiative is formally denied by voting - which is likely to happen during the upcoming plenary session of the Parliament in February - the Anti-BEPS Law would be unblocked for its signing and promulgation into law by the President of Ukraine. The Anti-BEPS Law introduces a number of fundamental novelties aimed at combating tax base erosion and profit shifting practices, improving transparency, tax compliance and administration, formally instituting the substance-over-form principle and other important anti-avoidance rules, generally modernizing the tax framework of Ukraine in vein with the OECD-driven initiatives. The new rules substantially alter the tax landscape for both Ukrainian individuals and legal entities as well as for non-residents that carry on business in Ukraine. Please note that no final draft of the Anti-BEPS Law is available thus far. This Legal Alert is based on the draft text of the Anti-BEPS Law prepared for the second reading by the Tax and Customs Policy Committee of the Parliament.
    [Show full text]
  • The Tax Code of Ukraine
    THE TAX CODE OF UKRAINE PART I. GENERAL PROVISIONS .............................................................................................................................. 13 CHAPTER 1. PRINCIPAL PROVISIONS .............................................................................................................................. 13 Article 1001. Scope of the Tax Code of Ukraine ...................................................................................................... 13 Article 1002. Tax legislation .................................................................................................................................... 13 Article 1003. Subjects of taxation ............................................................................................................................ 14 Article 1004. Object of taxation ............................................................................................................................... 14 Article 1005. Base of taxation .................................................................................................................................. 14 Article 1006. Tax rates and procedures for setting tax rates ................................................................................... 14 Article 1007. Establishment, abolition and application of tax exemptions .............................................................. 14 Article 1008. The procedure to calculate taxes ......................................................................................................
    [Show full text]
  • KPMG in Ukraine / 59 4 || Youryour Businessbusiness Inin Ukraineukraine 5 | Your Business in Ukraine
    Your Business in Ukraine Tax and Legal Guide January 2017 kpmg.ua 2 | Your Business in Ukraine Foreword Your business in Ukraine will help you discover new opportunities in challenging Ukrainian legislation landscape. We could guide you into currency control restrictions, dealing with licensing permits, protecting minority investors and other issues to simplify your day-to-day business decisions. Our practical guide provides insight into basics. It is Sergey Popov a compass to all stages of your business in Ukraine: Partner, Head of Tax market entry strategies, your company registration, and Legal Department taxation and other relevant information. Our industry expertise will help you to find effective practical solutions in Ukraine and abroad. Welcome in our Kyiv and Lviv offices for face-to-face meetings, our workshops on topical issues and business events. Konstantin Karpushin Partner, Head of Transfer Pricing Department, CIS Technology and Innovation Your Tax and Legal Contacts Ta x Legal Oksana Olekhova Yuriy Katser Director, Senior Counsel, Tax Services Legal Services T: +380 95 277 7525 T: +380 50 355 3470 E: [email protected] E: [email protected] 3 | Your Business in Ukraine Contents 1. Starting a business in Ukraine / 5 2. Company and Labor law / 9 3. Competition law / 17 4. Licensing requirements / 21 5. Taxation / 24 6. Financial reporting / 37 7. Property rights / 39 8. Currency regulations / 45 9. Customs regulations / 48 10. Winding-up/ Liquidation / 51 11. Dispute resolution / 53 Appendices Chart of withholding tax rates / 56 About KPMG in Ukraine / 59 4 || YourYour BusinessBusiness inin UkraineUkraine 5 | Your Business in Ukraine 1.
    [Show full text]
  • Al-Falah: Journal of Islamic Economics Journal Homepage: DOI: 10.29240/Alfalah.V4i1.781
    Content Lists Available at Directory of Open Access Journals (DOAJ) Al-Falah: Journal of Islamic Economics Journal Homepage: http://www.journal.iaincurup.ac.id/index/alfalah DOI: 10.29240/alfalah.v4i1.781 Ottoman Trade Policy and Activities in Europe and Asia Meirisona*, Desmadi Saharuddinb, Darni Yusnac aUniversitas Islam Negeri Imam Bonjol Padang bUniversitas Islam Negeri Syarif Hidyatullah Jakarta cUniveristas Islam Negeri Imam Bonjol Padang *Email: [email protected] ARTICLE INFO ABSTRACT Purpose: This discussion aims to provide an overview of Article History: Ottoman activities and policies in the field of trade and explain the factors that have led to support the economic progress and Received 11-02-2019 decline of this Empire. Revised 10-04-2020 Design/Method/Approach: This discussion uses a literature Accepted 09-06-2020 study with a content study approach (content analysis) that is Keywords: qualitative. Findings: Turkish Ottoman is traversed by an old trade route, Activities, Asia, which then develops into a country that is crossed by strategic Europe, Ottoman trade routes from East to West with various commodities, Trade including spices from Indonesia. One factor in the economic development of the Ottoman Empire is that the dense trade Paper Type: routes make this Ottoman state a political climate in Europe Research Paper and Asia. Treaties and treaties and foreign capitulations are given to European countries, which only pay a 3-5% tax. To reduce Western European pressure on the Ottoman Turks in dealing with the Hapsburg family. This made traders who were 80% made up of Muslim traders drastically reduced. The treaty that was signed was like a double-edged knife for the Ottoman Turks, which was of little use in the glorious days and harmful in the weak.
    [Show full text]
  • Significant Ukrainian Tax Changes for Multinational Companies
    Significant Ukrainian tax changes for multinational companies As updated on 22 January 2021 In brief The new laws introducing significant changes in the area of international taxation and transfer pricing (TP) ​ ​ ​ mostly related to the implementation of some BEPS Initiatives into Ukrainian tax legislation, entered into force. A variety of new concepts, terms and obligations await Ukrainian businesses and Multinational Enterprises (“MNEs”). Existing financing/corporate structures may appear inefficient under the new rules. ​ ​ Non-compliance might result in material fines for the businesses. ​ ​ The takeaway For MNEs and Groups that have business in/with Ukraine it is advisable to adopt immediate measures to ensure compliance with the new rules and still retain the efficiency of the business: ● Make an assessment of the current corporate structures to conclude whether they comply with the new tax law and remain efficient; ● Identify if the activities of the Group create any taxable presence in Ukraine (either through a permanent establishment (“PE”) or place of effective management (“PoEM”)) and take possible ​ ​ ​ ​ mitigation measures; ● Assess whether controlled and some other types of cross-border transactions have a business purpose, i.e. are aimed at receiving certain economic benefits; ● Assess whether the Group can enjoy double-tax treaty benefits under the new rules and prepare a defense file, if needed; ● Identify whether there is any Ukrainian controlling person in the Group (either an individual, tax resident of Ukraine,
    [Show full text]
  • Taxation of Permanent Establishments in Ukraine: Unresolved Issues
    Taxation of Permanent Establishments in Ukraine: Unresolved Issues Author(s): Vitalii Trachuk, Khrystyna Franchuk Source: Kyiv-Mohyla Law and Politics Journal 4 (2018): 159–174 Published by: National University of Kyiv-Mohyla Academy http://kmlpj.ukma.edu.ua/ Taxation of Permanent Establishments in Ukraine: Unresolved Issues Vitalii Trachuk National University of Kyiv-Mohyla Academy, Faculty of Law; Baker McKenzie Kyiv Khrystyna Franchuk National University of Kyiv-Mohyla Academy, Faculty of Law; Baker McKenzie Kyiv Abstract This article deals with selected issues of taxation of permanent establishments in Ukraine that lack appropriate judicial and scholarly attention. It particularly focuses on the attribution of profits to permanent establishments according to OECD standards and Ukrainian law, taxation of dependent agent permanent establishments, and the State’s taxing rights with respect to the permanent establishment’s financing by its head office. The authors conclude that to improve the quality of permanent establishments’ taxation in Ukraine, appropriate procedures should be clearly prescribed in the law and due regard be given to the already developed international standards that might be, in fact, directly applicable. Key Words: permanent establishment, taxation, attribution of profits, Authorized OECD Approach, tax convention. Introduction For decades, Ukrainian tax legislation has contained a provision prescribing the taxation of permanent establishments (PE). Being a party to a range of double taxation treaties after the collapse of the Soviet Union, Ukraine was forced to implement the concept of PE as most developed countries had for about a century.1 Since then, Ukrainian authorities have registered numerous representative offices of foreign enterprises as PEs and taxed them with Corporate Income Tax (CIT) accordingly.
    [Show full text]
  • Mechanisms of Environmental Taxation in Transition Globalizing Economies
    PERIODYK NAUKOWY AKADEMII POLONIJNEJ 20 (2017) nr 1 MECHANISMS OF ENVIRONMENTAL TAXATION IN TRANSITION GLOBALIZING ECONOMIES Lidia Shergina PhD, Associate Professor, SHEE “Kyiv National Economic University named after Vadym Hetman”, e-mail:[email protected], Ukraine Alla Zhemba PhD, Natіonal Unіvеrsіty of Watеr and Еnvіronmеntal Еngіnееrіng, e-mail: [email protected], Ukraine Abstract. The authors affirm that with the globalization of the world economy it is necessary to introduce the mechanism of environmentally sustainable economic functioning of the country. The article maintains that active use of environmental taxes must help to reduce the overall level of environmental pollution and increase production of environmentally clean products. Keywords: "green" economy, international integration, environmental taxation. DOI: http://dx.doi.org/10.23856/2011 Introduction Environmental taxation remains one of unsolved problems of nowadays. However, according to the scientists, we can establish the formation of the Institute of Ecological Taxes for today. O.O. Veklych, Z.S. Varnaluy, T.P. Galushkyna, V.S. Zagorodskuy, P.V. Melnyk, I.V. Rosputenko, I.M. Sinyakevych, K.I. Shvabuy, V.V. Yurchyshyn investigated theoretical and practical issues in the sphere of environmental taxation. The mechanisms of environmental taxation has not been worked out completely. The issues require further study in conditions of world economy globalization. The study is based on the use of systematic and integrated approaches to determine the main directions of forming the models of green economy as an element of sustainable development. The aim of this research is to determine global formation tendencies of environmental taxes to improve the ecological and sustainable development.
    [Show full text]
  • Doing Business and Investing in Ukraine
    www.pwc.com/ua Doing business and investing in Ukraine 2013 Edition Partner’s letter Contents I am very pleased to present the 2013 edition of our guide: Doing Business and 1 Country profile and investment climate 1 5.10 Customs audits 20 Investing in Ukraine. The guide is based on the laws as at 31 July 2013 and 5.11 Administrative issues 20 information made available through mid-July 2013. We prepared this new edition 1.1 Introduction 2 due to the number of significant changes that have been implemented since the 1.2 Government structure 2 6 Business entities 21 publication of our 2011 edition. 1.3 Legal system 2 6.1 Legal framework 22 1.4 People 2 6.2 Forms of business organisations 22 Ukraine, like many other countries in the region and around the globe today, 1.5 Economy 3 6.3 Net asset requirement 22 continues to face exceptional economic challenges. So far the country has weathered the storm better than many commentators had expected. Clearly, its 1.6 Foreign trade 4 6.4 Limited liability companies 22 geographic position and natural resources, as well as the ‘human factor’, have all 2 Business environment 5 6.5 Joint stock companies 23 played important roles in this achievement. Ukraine’s proximity to both the 6.6 Foreign directors 24 2.1 Business climate 6 European Union and Russia, the sheer quantity of its consumers (nearly 46 million) 6.7 Partnerships and joint activities 24 and the physical size of the country make it an excellent location for businesses to 2.2 Economic development plans 6 6.8 Branches 25 expand both locally and regionally.
    [Show full text]
  • Assignments to Europe WTS Assignments to Europe | Editorial WTS Assignments to Europe | Content
    Assignments to Europe WTS Assignments to Europe | Editorial WTS Assignments to Europe | Content Editorial In times of globalization, the importance of international employee de- Austria ................................................................. 04 Russia .................................................................. 53 ployment is growing. As a global company, you are therefore faced with the ever increasing complexity of managing your expatriates’ cross-bor- Belgium ............................................................... 06 Serbia .................................................................. 56 der taxation, social security, legal and immigration-related matters. The legal regulations in these fields are not only subject to constant change Bulgaria ............................................................... 09 Slovenia............................................................... 58 but they are also becoming more and more complex when applied in dif- ferent jurisdictions at the same time. Incorrect decisions can be both diffi- Croatia ................................................................. 11 Spain ................................................................... 60 cult and costly to rectify. Czech Republic ..................................................... 13 Sweden ............................................................... 62 At WTS, we can help you to identify cross-border work related risks at an early stage and optimize tax and social security payments for you and your Denmark ............................................................
    [Show full text]