The 2020 anti-BEPS tax reform as well as amendments to double tax treaties with Ukraine (primarily via MLI ratification) increase importance of substance for a foreign structure in jurisdiction of its tax residency.
For which structures is substance important? What are the options for enhancing substance? These questions will be discussed by KPMG experts during the webinar.
The webinar program includes questions:
- Application of double tax treaty benefits to payment of income to foreign structures with limited economic substance. Compliance with principal purpose test and beneficial owner rule
- Risks of tax residency/ permanent establishment in Ukraine for a foreign structure with limited economic substance
- CFC rules: exclusion from CFC income for structures with significant substance
- Ukrainian and foreign court practice on the necessary level of economic substance
- Which structures require to enhance economic substance?
- Which economic substance may foreign holding, financing and trading companies create?
KPMG speakers:
Oleksandr Boboshko, Director, Head of KPMG International Taxation Practice in Ukraine, Head of IT Business Sector
Andrii Buznytskyi, Manager, International Taxation Department, KPMG in Ukraine
Participation in webinars is free. Applications for participation from consulting, law and audit companies are not accepted. The organizers reserve the right to refuse registration at the event for participants whose companies cannot be identified.
Language: Ukrainian
If you have any questions, please contact Yulia Salei: ysalei@kpmg.ua
