The Ukraine State Fiscal Service has issued guidance letter 2626/6/99-00-05-05-02-06/IPK of 1 July 2020, which clarifies the application of the new rules for the determination of taxable income (profit) of a permanent establishment (PE). Ukraine's PE rules were amended in line with OECD standards as part of Law No. 466-IX, published 22 May 2020.
The guidance letter provides that a PE is equated for tax purpose as a taxpayer conducting activities independently of the non-resident parent, with…