Tax position of non-taxable representative offices of foreign companies in Ukraine

Representative offices of foreign companies in Ukraine have historically been a favourite target of the Ukrainian tax authorities.

Based on the fiscal interpretation of Ukraine’s tax code, the tax authorities attempt to tax financing from the head company in the hands of the representative office even if the latter should not constitute a permanent establishment (PE) by virtue of applicable treaty protection.

Existing court practice in Ukraine shows a tendency of courts contesting the tax authorities’ position by, among other things, referring to principles of international taxation as envisaged in Ukraine’s double tax treaties…

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