On the trail of the beneficiary

Judicial practice of applying the concept of beneficial owner support classical models of tax planningInspiration for the conceptThe concept of beneficial owner appeared in the domestic legislation , as you know, due to the desire of the tax authorities to find an effective tool to combat " tax schemes " and the wave of inspiration from information cooperation with the tax authorities of the Netherlands. Last supposedly in 2010 confirmed the status of non- financial institution under the law of the Netherlands at the entity with which the Ukrainian company paid interest on the loan and taxed them at a reduced rate (2 % instead of the normal income tax rate for non-residents - 15%).


VAT: is it easier?

The practice of applying the changes in the registration of the VAT payer, the proposed Law of Ukraine # 4834 «On amendments to the Tax code of Ukraine regarding the improvement of some tax rules (hereinafter - the «Law # 4834) is not unambiguous. Its adoption led to many questions: who can be registered as a VAT payer? A list of documents will be required in practice for the voluntary registration? What can be the grounds for refusal of registration?
It is worth Recalling that the tax authorities declared simplification of procedures of tax administration and reduction of bureaucratic barriers to entrepreneurs. Today becomes obvious, that reduction of bureaucratic procedures is another link in the whole chain of «simplification», which is very questionable.

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