On April 18 of this year KPMG in Ukraine held a seminar "Transfer pricing in Cyprus: what Ukrainian taxpayers need to know". During the event, Konstantin Karpushin, Partner, Head of the Transfer Pricing Services Group, Vladimir Chizhikov, Senior Manager of the Transfer Pricing Group and Maria Petrova, Senior Consultant of the transfer pricing group KPMG in Ukraine, spoke during the event.
According to the NBU, Cyprus Company issued 50% of all loans received by Ukrainian payers. Interest for the use of such loans, when the cost criteria are achieved, are subject to control by the tax authorities in terms of the TCS. However, many payers forget that such interest is also controlled in Cyprus. Ignoring bilateral control can lead to the fact that in one of the jurisdictions (Ukraine or Cyprus), the interest rate may not correspond to the principle of "outstretched hand" and the payer can get under double taxation and / or sanctions of the tax authority.
The seminar brought together more than 100 representatives of leading Ukrainian and international companies and about 80 participants had the opportunity to join the live broadcast of the event.