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On Monday, October 9, Deputy Minister of Finance of Ukraine Sergey Marchenko and the Minister of Economy of the Republic of Turkey Nihat Zeibekci signed the Protocol on amendments to the Agreement on avoidance of double taxation between the two states. The adopted innovations will allow physical and legal persons to avoid paying double taxes on the income received in the territories of Ukraine and Turkey. This can be achieved with the help of the distribution of the right to tax certain types of income depending on the place of their origin between the two countries, as well as by taking into account the taxes paid in the territory of another state in the tax obligations of the taxpayer of one state. It is expected that the changes will create better conditions for the investors of both jurisdictions and they will increase the entrepreneurial initiative. The settlement of the issue of international taxation of income in bilateral relations between Ukraine and Turkey will help eliminate tax discrimination, as well as establish cooperation between the tax authorities of the states and the exchange of tax information. The signed Protocol provides: expansion of the meaning of the...

On October 9, Ukraine and the United Kingdom of Great Britain and Northern Ireland amended the Agreement on avoidance of double taxation, provided for by the relevant Protocol. This was reported by the press service of the Ministry of Finance. The amendments to the agreement are aimed at exemption of the physical and legal entities from paying double taxes on incomes received in the territories of both parties. This can be achieved both by distributing the right to tax certain types of income depending on the place of their receipt between the two countries, and by taking into account the taxes paid in the territory of the other country in the tax obligations of a taxpayer of one country. It is expected that the signing of the Protocol will contribute to the creation of the favorable conditions for the investors in Ukraine and the United Kingdom, as well as to increase the business initiative of the entrepreneurs. The settlement of income taxation in bilateral relations between Ukraine and Great Britain will allow to eliminate tax discrimination, to ensure the exchange of tax information and improve the cooperation between the tax authorities of the states through the development...

The Federal Council of the Swiss Confederation adopted the Ordinance on the automatic exchange of country-by-country reports, which will enter into force on December 1, 2017 as an addition to the Federal Law on the automatic exchange of country-by-country reports of the transnational companies. It should be mentioned that this Law and the Multilateral Agreement of the competent authorities on the exchange of the intercountry reports to date are the legislative base of Switzerland for the automatic exchange of financial information with other states. The adopted Ordinance introduces a requirement for transnational companies that operate in Switzerland, to compile country-by-country reports on an annual basis starting in 2018, as well as fixes the content of these reports. Switzerland will begin the exchange of country-by-country information in 2020. As the Federal Council assures, this decision is designed to bring the legal basis of the state in line with one of the international standards for preventing the base erosion and profit shifting, the purpose of which is to ensure transparency of taxation of transnational companies and the development of a unified concept for the...

On October 4, 2017, from 10-00 a.m. to 1-00 p.m., in the premises of the Supreme Administrative Court of Ukraine, a round table was held on the topic "Current problems of administrative law in tax disputes". The event was held in the format of reports on specific topics. At the meeting, the attention was focused on who should nevertheless act as a respondent in the disputes related to the refusal in the registration of tax bills, and what requirements the statements of claim should contain for effective protection of the violated right. In addition, it was noted that the provisions of by-laws adopted by the Cabinet of Ministers of Ukraine and the Ministry of Finance of Ukraine are not fully in line with the norms of the Tax Code of Ukraine, which regulate the issues of suspension of the registration of tax invoices. The opinion was expressed (which is difficult to disagree) that the introduction of an automatic blocking of the tax bills, in fact, repeated the idea of ​​unilateral termination of agreements "on the recognition of electronic documents", which the fiscal authorities used for the refusal in the registration of the tax bills. In addition, the aspect of proof in the...

On August 30, 2017, an international team of researchers notified the Estonian government of a security vulnerability of the ID cards issued to around half of the Estonian population. The potential risk concerns the ID cards issued since October 2014 (including cards issued to e-residents), i.e. about 750,000 cards. In this regard, the Department of the Estonian Information System Authority has taken temporary measures to restrict some features of the ID cards of this period of release. Since there were no real cases of unauthorized use of the ID cards, today the vulnerability is theoretical. A security breach was discovered in connection with the advancement of the “e-Estonia” national initiative, designed to bring citizens into the digital ecosystem of public and private services built upon the security and authentication. The Estonian ID card unifies access to a host of services. Using this card, the citizens can carry out banking operations, vote, file their tax returns, apply for state benefits, apply to serve in the armed forces and fulfil many other actions remotely. Business owners can use the ID cards to file their annual reports, apply for licenses, and so on,...

The Ministry of Finance of Ukraine has developed a solution that will improve the operation of the system of registration suspension of the TI and it will allow to avoid blocking of the TI of the real sector of the economy. The innovation mainly relates to the agricultural sector, since the increase in the percentage of "blockages" has been recorded in it recently. We remind that since July 1, the system of automated registration of tax invoices has begun to work in full force, designed to prevent billions of twists with VAT and to counter the receipt of tax credits by the unscrupulous payers. However, the practice shows that due to inadequate operation of the system, the honest Ukrainian business sometimes suffers. According to the results of daily monitoring of the system's operation in the context of different branches, the Ministry of Finance discovered a significant increase in the number of suspended tax invoices of the payers of the real sector in the sphere of agriculture, forestry and fisheries. In June 2017, the share of the invoices issued in this industry was 5% of the total number of suspended TI/ AC, in July - 18%, and in August - 29%. After holding a series of...

In connection with the leaving of the UK from the European Union, one of the largest Singaporean banks, Oversea-Chinese Banking Corporation, is planning to open its branch in Luxembourg. Earlier, the European branch of OCBC was located in London, which allowed the bank to manage affairs in the EU. Now the banking corporation is considering Luxembourg as a convenient place for doing business, where it intends to open a new branch. The implementation of this plan will be a very significant event in the financial history of the Grand Duchy. However, it should be noted that the decision is not final yet and the bank is also considering other jurisdictions. It is expected that the situation will become clear after the announcement of the results of the meeting of the Executive Director of OCBC Bahrain Shaari and the Prime Minister of the Grand Duchy Xavier...

On September 27, the Minister of Finance of Ukraine, Alexander Danilyuk, met with the representatives of the Organization for Economic Cooperation and Development (OECD) to discuss the implementation of the Action Plan on Base Erosion and Profit Shifting (BEPS) and joining of Ukraine to the automatic exchange of information between fiscal authorities (AEOI standard). With this visit, the OECD representatives launched the first common program for the implementation of the international standards for information exchange and BEPS activities. According to Alexander Danilyuk, the Ministry has developed a detailed Roadmap for the introduction of the Minimum Standard of the Plan, according to which Ukraine will join the MLI (Multilateral Instrument) before the end of this year. The implementation of the Steps 6 and 14 of the Minimum Standard of the Plan will contribute to improving the mechanisms for combating the artificial use of the additional benefits of the international conventions in order to exempt profits from taxation. The corresponding amendments will be introduced in more than 60 existing international conventions on the avoidance of double taxation. It is also worth noting...

De-offshoring process is gaining momentum. The pressure from the Organization for Economic Cooperation and Development (OECD) is increasing to which the offshore jurisdictions are subjected. Thus, at the request of the OECD, the changes in the Law on International Commercial Companies (hereinafter the Law) have entered in force since July of this year in Belize. Among the main innovations are: the obligation to maintain a register of the beneficial owners and the register of the directors, as well as a ban on the issue or exchange of the bearer shares. Register of beneficial owners Unlike many other jurisdictions, in Belize, this obligation was realized with the requirement to store data on the beneficiaries only at the company registration address. As a rule, this is the address of the registration agent. But there is no requirement to submit data from this register to the state register of the companies. At the same time, it is not necessary to provide historical information - only the data of the current beneficiaries of the company are entered in the register. The term "beneficial owner" is defined as an individual: - who owns or ultimately controls the company; - ...