OMP Events
Webinar
Representative
offices of
non-residents,
come on, goodbye!
Or six months` experience of
a new public policy
regarding representative offices.
ZOOM
ZOOM
Dear friends, colleagues, partners!
We continue to announce the webinars of our autumn series of events “From the life of Pharm industry 2021” and sincerely invite you to join us and figure out the intricacies of the law, and more.
SO, THE 2ND WEBINAR FROM OUR CYCLE:
Representative offices of non-residents, goodbye! Or six months` experience of a new public policy regarding representative offices: what to do and whether it is possible to adapt to change?
PROGRAM
• New practice of tax inspections - total denial of the right of representative offices to tax benefits or "all representative offices are permanent": argumentation of tax authorities, strategies to protect representative offices, the position of the Business Ombudsman's Office, interim results of appeals against inspection results;
• International inquiries of the Ukrainian tax authorities as an important component of recognizing non-resident representative offices as permanent: detailed analysis of typical questions and possible answers, comments on optimal approaches to work with head offices in preparing answers to inquiries of the Ukrainian tax office;
• Saga with tax registration of non-residents that have offices in Ukraine: arguments for and against the registration of companies that do not have permanent offices in Ukraine, a new tax position, options for future behavior;
• Changes in approaches to tax benefits for representative offices around the world and their impact on Ukrainian realities - the "warm bath" for the use of priviledged representative offices is coming to an end (and this is an international trend): we analyze recent changes in OECD comments on the double convention on avoiding double taxation and their interpretation by Ukrainian tax office, discuss the impact of BEPS rules on permanent representative offices, develop a safe course of action for the future;
• Pros and cons of using permanent representative offices for non-residents in Ukraine: we analyze changes in the last two years in approaches to reporting of permanent representative offices and non-residents in Ukraine, discuss the consequences of abolishing the simplified taxation of permanent representative offices, explore the risks of expanding parent company (based on the results of recent inspections of non-resident representative offices by the Ukrainian tax authority);
• Options for minimizing the risks of using representative offices in Ukraine: from full transition to the use of Ukrainian subsidiaries to partial use of priviledged representative offices - analyze the pros and cons of working through representative offices in view of recent changes in tax policy of Ukraine;
• The main stages of transformation or liquidation of representative offices in Ukraine or how not to make it worse: we analyze the recent practice of inspections of representative offices by Ukrainian tax authorities that have changed their tax status to permanent, and representative offices in the process of liquidation.