It seems that Law No. 466-IX (more known as “KIK” – “The Rules of Taxation for Controlled Foreign Companies”) starts working. Tax officers warn about the beginning of inspections of non-residents starting with July 2021. And non-residents carrying out their activity in the Ukrainian territory without LLC registration are adjusting to the new reality.
Question No. 1. How will the STS calculate non-resident’s profit from which tax is to be paid? The answer is rather vague, but still: it is necessary to calculate the profit an independent LLC would get it if carried out similar activity.
We advise to plan optimization of your structures for the nearest period possible, since, in case of inspections, the sanctions will be imposed already starting with January 1, 2021.