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11.03.21, Bosco Online Workshop “Banking, Company Set-Up, Taxes”:

Thursday, 25 March 2021

On March 11, Bosco Online Workshop “Banking, Company Set-Up, Taxes” was held, where international experts and more than 250 listeners from 40 countries participated.

The following topics were discussed at the conference:

Tax amnesty on capital - should you take an opportunity that comes only once every 30 years?! - Olga Trifonova, Private Wealth Leader and Julia Kadibash, Private Wealth Practice at PwC Ukraine;

Payment Service Provider PAYSTREE LTD. Feel quick, safe and easy with us! - Igors Moisejenko, Partner Relationship Manager at PAYSTREE LTD;

The main tax risks in international transactions. - Larisa Antoshchuk, Senior Manager, Head of Tax Dispute Resolution Practice at KPMG Ukraine.

Immigration Abroad: Tax Implications in Russia. - Anastasia Ivanchikhina, Manager at ALTHAUS Private Tax.

Olga Trifonova and Yulia Kadibash, PwC Ukraine, spoke about all the nuances of the tax capital amnesty.

Few facts about the tax amnesty:

In Ukraine, a tax amnesty is a capital amnesty, since it provides an opportunity to declare assets in Ukraine and/or abroad, acquired from income from which taxes have not been paid, and have not been declared during any tax period in the past.

Tax amnesty is carried out by filing a special declaration and paying a special fee from a one-time special declaration. State guarantees are provided to declarants. The ability to legalize your condition before the introduction of cost control and automatic exchange of information.

Who can benefit from this amnesty:

- Individuals - residents;

- Individuals - non-residents who were residents at the time of the acquisition of assets / receipt of income;

Persons who, during any year, starting from January 1, 2005, have filed or must file a declaration in accordance with anti-corruption legislation, cannot submit a declaration.

Declaration process:

- The form for filing a special declaration is only electronic

You can submit a special declaration:

- personal;

- impersonal - through a notary;

- close persons of e-declarants can submit only personal special declarations.

Depersonalized submission - how is it?

- When submitting an impersonal declaration, an electronic special declaration for an individual will be submitted by a notary with whom an agreement has been concluded for the provision of such services;

- The notary keeps the original of the special declaration and supporting documents signed by the declarant;

- The declarant is assigned a special identifier (alphanumeric code).

What is being declared?

Assets in Ukraine and/or abroad acquired from income from which taxes were not paid as of January 1, 2021, including:

- currency values ​​(including the right to claim money);

- real estate;

- movable property;

- corporate rights;

- Central Bank and other fin. tools;

- the right to receive property benefits;

- other assets.

Igors Moisejenko, PAYSTREE LTD, spoke about the advantages of the payment service provider PAYSTREE LTD as an alternative to banks.

The speaker named the main advantages of PAYSTREE LTD, which will definitely interest potential customers:

- Online registration;

- Convenient interface;

- Secure web interface;

- Direct SWIFT payments;

- Friendly fintech banking;

- Mobile application for iOS and Android.

Igors spoke about the services and products that PAYSTREE LTD can offer:


- Private client;

- Client's business;

- EU residents/non-residents;

- Individual IBAN account.


- SEPA payments;

- SWIFT payments;

- Payment currencies: EUR, USD, RUB, CNY (opportunities for currencies will expand);

- Direct multicurrency IBAN;

- A developing network of correspondent banks and financial institutions.


- Personal service for each client;

- Payment cards for private clients, EU/EEA residents;

- Internet acquiring;

- Development of white label projects.

Larisa Antoshchuk, Senior Manager, Head of Tax Dispute Resolution Practice, KPMG Ukraine, spoke about the main tax risks in international transactions.

On the issue of classic risks, the Speaker identified two groups of problematic points for a business that works in Ukraine or with Ukrainian companies.

The first point is related to preferential tax rates for non-residents' income.

The second point is the question of the economic essence of transactions, the presence of an economic presence with a non-resident, the recipient of passive income with a source of origin in Ukraine, as well as whether the beneficial owner, in the understanding of the tax code and the convention for the avoidance of double taxation, is the recipient of income abroad.

According to the Speaker, several laws passed in 2020 have significantly helped the fiscal authority to check business representatives. In 2020, a small tax reform was carried out that affected the BEPS taxation (erosion of the tax / tax base and the withdrawal of income/ profits from taxation).

The courts have not fully tested these requirements that were introduced:

- Economic feasibility of the operation: assets, risks, functions, employees, physical office, place of management, turnover; economic reason for the transaction.

- Regulation of transfer pricing: verification of related parties, additional methodology and types of controlled transactions; new reporting standards; reasonable economic content.

- Recognition of a permanent establishment (PP) - agency and trade (based on the content of activities not provided for by the agreement, power of attorney); reclassification of representative offices, individuals into individual entrepreneurs. Property confiscation risk.

- Regulation of controlled foreign companies: reporting and taxation issues.

Anastasia Ivanchikhina, Manager, ALTHAUS Private Tax, spoke about immigration abroad, as well as the tax implications in Russia.

The speaker spoke about tax residency in Russia:

Tax resident of Russia:

An individual (regardless of citizenship) who actually stays in Russia for at least 183 days during the next 12 months in a row.

In the "Main directions of tax policy for 2020-2022." The Ministry of Finance proposed new criteria - to reduce the number of days spent on the territory of the Russian Federation to 90.

Nuances of tax residency in Russia:

  1. In the event of a disputable situation, the provisions of the DTT may be applied to determine the tax status.
  2. In some cases, a short-term (less than 6 months) absence from the territory of Russia may not be counted for tax purposes (for example, departure for medical treatment).
  3. A special rule for 2020: an individual can recognize himself as a resident of the Russian Federation upon application if he has spent more than 90 days in Russia.

Anastasia also spoke about income from sources in Russia. An individual who is a tax non-resident in the Russian Federation can receive income from:

Real estate in the Russian Federation:

- Rent payments;

- Income from the sale of real estate.

Income from Russian companies:

- Dividends;

- Income from the sale of shares / shares in the company;

- Interest on loans.

Portfolio investment income:

- Dividends on shares of Russian companies;

- Coupon on Russian bonds;

- Income from sale / redemption (Russian and foreign securities).

Other income from sources in Russia:

- Salaries in the Russian Federation, directors' remuneration, etc.

DTT may establish that income is subject to:

- Only in the jurisdiction of residence of an individual (exemption in the Russian Federation);

- In both jurisdictions, but with the possibility of offsetting (i.e., tax paid in the Russian Federation is deducted from the amount of tax payable in the jurisdiction of residence).

Benefits provided under DTT:

- Reducing the tax rate;

- Tax offset;

- Liberation.

More detailed information about the event is available by the link:


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