The State Tax Service of Ukraine recently issued a release announcing that as part of the cooperation project with the EU, Ukraine is preparing to implement a general anti-abuse rule (GAAR) that is based on the GAAR provided in the EU Anti-Tax Avoidance Directive (ATAD1), Council Directive (EU) 2016/1164. The ATAD GAAR essentially provides that, for the purposes of calculating corporate tax liability, the tax authority may ignore an arrangement or a series of arrangements that have been put…