Приклади вживання Permanent representative office Англійська мовою та їх переклад на Українською
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Permanent Representative Office.
Opening of a foreign company permanent representative office in Ukraine;
Profit tax of foreign organizations which donot carry out activities in the Republic of Belarus through a permanent representative office.
The Foundation has its permanent representative offices in Warsaw and Brussels.
Profit tax of foreign organizations which donot carry out activities in the Republic of Belarus through a permanent representative office.
The Foundation has its permanent representative offices in Warsaw, Kyiv and Brussels.
Amendments to double tax treaties, EU blacklists, transfer pricing,beneficial owner of income, permanent representative office.
Therefore, due to permanent representative office in Asia Pacific region you can easily purchase turnstiles and road-blocking systems at a bargain price!
Economic transactions between the non-resident and its permanent representative office in Ukraine.
In case of the provision of services by a non-resident- its permanent representative office or, lacking the same, the entity, which receives such services, if the place of the provision of such services is located on the customs territory of Ukraine;
Income tax of foreign organizations not performing activities through the permanent representative office in the territory of Belarus.
The Permanent Representative Office of the non-resident of Ukraine(hereinafter-the permanent representation) is a permanent activity, through which fully or partially carried out business activities of non-resident on the territory of Ukraine.
Then within 10 days the StateTax Service must decide on deregistering of a permanent representative office as an income taxpayer in the register of non-resident taxpayers.
The controlled transactions were supplemented with a new subsection“ґ”, which includes“business transactions,which are carried out between a non-resident and its permanent representative office in Ukraine.”.
In general, for a non-resident operating in Ukraine through a permanent representative office, the Tax Code of Ukraine provides for 3(three) methods of determining taxable income subject to taxation in Ukraine.
The criterion for choosing this method is the statement that a non-resident carries out its activities in Ukraine and abroad andthat does not determine the income from its activities carried out through its permanent representative office in Ukraine.
The taxable item is: the difference between separate income of a permanent representative office(obtained by calculation)and the costs borne by a permanent representative office(clause 2 Section II of Regulation No. 544).
This statutory provision was amended in 2019, and currently the concept of economic transactions for transfer pricing purposes,conducted between a non-resident and its permanent representative office in Ukraine, also includes internal economic settlements.
Since Ukraine got independent in 1991,BETEN had created there its Permanent Representative Office and has been developing numerous projects in different sectors in this country which territory is 10% larger than the territory of France.
The criterion for choosing this method is the statement that a non-resident carries out its activities in Ukraine and abroad andthat does not determine the income from its activities carried out through its permanent representative office in Ukraine.
From 2018, economic transactions conducted between a non-resident and its permanent representative office in Ukraine are recognized as controlled ones if the total volume of such transactions, as determined under accounting rules, is more than UAH 10 million.
Larysa Vrublevska also discussed the inventory of controlled transactions for 2018, paying attention to the details of calculating the cost criterion,and focused on the issue of business transactions between a non-resident and his permanent representative office in Ukraine, told about the features of the List of CMU No. 480 and No. 1045.
In the case of a permanent representative office, the economic transactions between a non-resident and its permanent representative office in Ukraine shall be considered controlled if the amount of such transactions exceeds UAH 10 mln per year(net of VAT and excise duties).
At the same time,the economic transactions with non-residents(save for the transactions between the non-resident and its permanent representative office in Ukraine) shall simultaneously meet the following conditions:.
Additionally a permanent representative office(ideally this is a representative office through which economic activities of a foreign company are conducted but in practice all kind of representative offices are used) must be registered as an income taxpayer.
Documentary evidence or justification that the method and purpose of acquisition does not require establishment by such company(organization)of a separate division or a permanent representative office of the non-resident in Ukraine, and that possession of such property by a foreign company is temporary and will be followed by alienation.
The place of registration of the buyer or its permanent representative office or, lacking such a place of registration- the place of the permanent address or permanent residence, if the buyers, to which the services listed below are provided, live outside the customs territory of Ukraine and provide the services.
Larysa Vrublevska, Partner, Transfer pricing Manager, EUCON International Legal Center, stopped on the problems of practical application of legislation and controversial rules andtalked about business transactions between a non-resident and his permanent representative office in Ukraine, when the financing of the activity of the representative office can be recognized as a controlled transaction, in connection with these permanent representative offices in Ukraine should be prepared to confirm such transactions as services provided to a non-resident.
The speaker noted that control over transactions between a non-resident and its permanent representative office was introduced, for the purposes of calculating the value criterion of UAH 10 million the volume of business transactions determined by the principle of“arm's length” is taken into account.
Starting from 2018, the list of controlledtransactions was expanded by transactions between a non-resident and its permanent representative office in Ukraine, if the volume of such transactions, determined according to accounting rules, exceeds 10 million UAH(after deduction of indirect taxes) for the corresponding tax(reporting) year.