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Taxation of Permanent Establishments in Ukraine: Unresolved Issues

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Type: Journal Article
Author: Trachuk, Vitalii; Franchuk, Khrystyna
Journal: Kyiv-Mohyla Law and Politics Journal
Page(s): 159–174
Date: 2018
URI: https://hdl.handle.net/10535/10589
Sector: Social Organization
Region: Europe
Subject(s): LAW
Abstract: This article deals with selected issues of taxation of permanent establishments in Ukraine that lack appropriate judicial and scholarly attention. It particularly focuses on the attribution of profits to permanent establishments according to OECD standards and Ukrainian law, taxation of dependent agent permanent establishments, and the State’s taxing rights with respect to the permanent establishment’s financing by its head office. The authors conclude that to improve the quality of permanent establishments’ taxation in Ukraine, appropriate procedures should be clearly prescribed in the law and due regard be given to the already developed international standards that might be, in fact, directly applicable.

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