The Ministry of Finance of Ukraine has reminded that as of January 1 of the reporting year 2025, an updated list of states (territories) for transfer pricing purposes came into force.
The Ministry notes that this is provided for by Law No. 3813-IX, adopted on June 18, 2024, on the peculiarities of tax administration during martial law for taxpayers with a high level of voluntary compliance with tax legislation. The list itself was approved by Resolution of the Cabinet of Ministers No. 1505 of December 27, 2024.
It is noted that when determining the list of states for transfer pricing purposes, the Government of Ukraine takes into account the following criteria states (territories) included in the list of offshore zones approved by the Cabinet of Ministers; states (territories) included in the list of states (jurisdictions) that do not implement or improperly implement the FATF recommendations; states (territories) whose competent authorities, based on the results of two consecutive reporting (tax) periods (years), do not ensure timely and complete exchange of information on tax policy with taxpayers, as well as do not exchange data on tax risks.
The Ministry of Finance believes that these changes are important for Ukrainian business, as they relate to the effective management of transfer pricing risks to ensure the financial stability of companies.
As reported, the updated list of states (territories) contains 46 states (territories) instead of 78. The list includes countries from the list of offshore zones approved by the government and the FATF blacklist. FATF, as well as states (territories) that do not ensure timely and complete exchange of tax and financial information.
We are talking about 9 states and territories: American Samoa, Guam, the DPRK, Myanmar, Namibia, the Netherlands Antilles, Alderney, Trinidad and Tobago, and Fiji.
According to the resolution, 41 countries or territories were removed from the list, including: Bahrain, Bosnia and Herzegovina, Brunei, Burundi, Cape Verde, Cape Verde, China Hong Kong Special Administrative Region (EU), Djibouti, Dominican Republic, Ireland, the Autonomous Community of the Canary Islands of the Kingdom of Spain, Cuba, Guadeloupe, Guatemala, Kyrgyzstan, Cyprus, the Autonomous Province of Kosovo and Metohija of the Republic of Serbia, Cuba, Curacao, Laos, Lebanon, Mauritius, and Qatar.
The list also includes the Macao Special Administrative Region of China, the Former Yugoslav Republic of Macedonia, the Federated Territory of Labuan Malaysia, Morocco, Martinique, and the Federated States of Micronesia, Moldova, Montenegro, Oman, Paraguay, the Commonwealth of the Northern Mariana Islands, the Autonomous Region of Madeira of the Portuguese Republic, San Marino, Sao Tome and Principe, Sudan, Timor-Leste, Turkmenistan, Uzbekistan and the United Arab Emirates.
Source: http://relocation.com.ua/ministry-of-finance-updated/
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