The Ukraine State Fiscal Service has issued guidance letter 3380/IPK/99-00-05-05-02-09 regarding the new rules for the taxation of profits of controlled foreign companies (CFCs), which apply from 1 January 2021.
Under the new CFC rules, the adjusted profit of CFC will be included in the taxable income of a controlling person in Ukraine in proportion to the share of the CFC owned or controlled by the controlling person on the last day of the relevant reporting (tax) year. However, the letter…