Taxation of Permanent Establishments in Ukraine: Unresolved Issues

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 ag...

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Main Authors: Vitalii Trachuk, Khrystyna Franchuk
Format: Article
Language:English
Published: National University of Kyiv-Mohyla Academy 2018-09-01
Series:Kyiv-Mohyla Law and Politics Journal
Subjects:
Online Access:http://kmlpj.ukma.edu.ua/article/view/153258/152638
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author Vitalii Trachuk
Khrystyna Franchuk
author_facet Vitalii Trachuk
Khrystyna Franchuk
author_sort Vitalii Trachuk
collection DOAJ
description 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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spelling doaj.art-b6744b440ac64cf59f03cf933988246d2022-12-21T23:45:40ZengNational University of Kyiv-Mohyla AcademyKyiv-Mohyla Law and Politics Journal2414-99422018-09-01415917410.18523/kmlpj153258.2018-4.159-174Taxation of Permanent Establishments in Ukraine: Unresolved IssuesVitalii Trachuk0Khrystyna Franchuk1National University of Kyiv-Mohyla AcademyNational University of Kyiv-Mohyla AcademyThis 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.http://kmlpj.ukma.edu.ua/article/view/153258/152638taxationtaxoecdtax conventionattribution of profitspermanent establishment
spellingShingle Vitalii Trachuk
Khrystyna Franchuk
Taxation of Permanent Establishments in Ukraine: Unresolved Issues
Kyiv-Mohyla Law and Politics Journal
taxation
tax
oecd
tax convention
attribution of profits
permanent establishment
title Taxation of Permanent Establishments in Ukraine: Unresolved Issues
title_full Taxation of Permanent Establishments in Ukraine: Unresolved Issues
title_fullStr Taxation of Permanent Establishments in Ukraine: Unresolved Issues
title_full_unstemmed Taxation of Permanent Establishments in Ukraine: Unresolved Issues
title_short Taxation of Permanent Establishments in Ukraine: Unresolved Issues
title_sort taxation of permanent establishments in ukraine unresolved issues
topic taxation
tax
oecd
tax convention
attribution of profits
permanent establishment
url http://kmlpj.ukma.edu.ua/article/view/153258/152638
work_keys_str_mv AT vitaliitrachuk taxationofpermanentestablishmentsinukraineunresolvedissues
AT khrystynafranchuk taxationofpermanentestablishmentsinukraineunresolvedissues