Ukraine Issues Guidance Letter Clarifying Application of 30% Adjustment for Transactions with Tax Havens and Non-Taxed Entities

The Ukraine State Fiscal Service has issued guidance letter 2654/6/99-00-05-05-02-06/IPK regarding the application of the 30% adjustment (increase) in taxable income in relation to deemed controlled transactions with residents of low-tax jurisdictions (tax havens) and with non-residents that are not subject to tax in the jurisdiction in which they are based or not resident for tax purposes in the jurisdiction in which they are registered. In particular, the letter addresses transactions invol…