Illya Sverdlov was a tax partner at DLA Ukraine. He still would be there, but DLA a year ago announced it leaves Ukraine. So, Illya with all the tax team moved to Kinstellar law firm, which is a Tier 1 firm in tax in Ukraine by Legal 500 directory.
Politics
While the media mostly talks of the potential
war in Ukraine, Illya feels quite confident that everything politically is more
or less stable, considering the circumstances. People are not panicking and
feel more prepared than during the previous conflict with Russia in 2014. Then
Ukraine had a mobilisation of all men, whereas now it has not happened so far. Nevertheless
everybody checks in to the military units and even takes some shooting
practice.
Business
There is no downturn, quite on the
opposite. The investments have not stopped, nor are exiting. The corruption
situation is also getting better since 2014 reform. The scale of the grey
economy has been reduced as well lately. I could feel that the politics and
business in general were not comfortable topics for Illya right now as there is
so much uncertainty. But the tempo of the discussion changed once we switched
to tax.
Tax
Ukraine as of 2022 has introduced CFC
rules. The place of effective management and the beneficial ownership rules may
require foreign companies with management in Ukraine to restructure. Foreign
holding companies through the foreign tax authorities now receive long lists of
very detailed questions from the Ukrainian authorities in order to determine, if
the cross-border taxation was correctly applied. The Ukrainian authorities are
getting smarter. The corporate structure should be as simple as you can explain
to a child. Either one should create substance in the foreign company or close
it.
One of the best tax systems for IT
companies
“One of the world’s
best tax systems is now available for small startups as well as big IT
companies at any location across Ukraine,” said Minister for Digital
Transformation Mykhailo Fedorov[1]. IT companies in Ukraine as of 2022 can pay either 18% corporate tax
or pay no CIT until distribution of profits when 9% CIT is applied. Salaries of
employees of such companies are taxed at 6.5% income tax, and the social
contributions are capped at just USD 50 a month. At least USD 1200 salary
should be paid to the employees and the company must have at least 9 employees.
Now it seems at least as competitive as the tax system in the High Technology
park in Belarus.
Purple cow is having no purple cow
Illya thinks the best marketing of a tax
advisor is recommendation once the firm has done a good job and the client is
happy, as tax lawyers are handling very delicate matters of their clients.
[1] Over 50 IT companies
join Ukraine’s ‘special tax regime’ Diia City in first three days (as of
11.2.22.), incl. Revolut:
Nav komentāru:
Ierakstīt komentāru