Taxation of Permanent Establishments in Ukraine: Unresolved Issues
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Date
2018
Authors
Trachuk, Vitalii
Franchuk, Khrystyna
Journal Title
Journal ISSN
Volume Title
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Abstract
This article deals with selected issues of taxation of permanent establishments in
Ukraine that lack appropriate judicial and scholarly attention. It particularly focuses
on the attribution of profits to permanent establishments according to OECD standards
and Ukrainian law, taxation of dependent agent permanent establishments, and the
State’s taxing rights with respect to the permanent establishment’s financing by its head
office. The authors conclude that to improve the quality of permanent establishments’
taxation in Ukraine, appropriate procedures should be clearly prescribed in the law
and due regard be given to the already developed international standards that might
be, in fact, directly applicable.
Description
Keywords
permanent establishment, taxation, attribution of profits, Authorized OECD Approach, tax convention, article
Citation
Trachuk V. Taxation of Permanent Establishments in Ukraine: Unresolved Issues / Vitalii Trachuk, Khrystyna Franchuk // Kyiv-Mohyla Law and Politics Journal. - 2018. - No. 4. - P. 159-174.