The new week is the best opportunity to start studying within the new course “Taxation Novels” of the School of Tax Practice by Legal High School, which has started today, May 25. The first module of the course started with the speech of Yaroslav Romanchuk – an attorney and a managing partner of the EUCON Legal Group. Students of the module had the opportunity to hear practice leaders` expectation the tax changing in the near future due to the adopted law №1210, what should to be done to bring the company in line with new rules, as well as new M&A tax rules -agreements, implementation of the BEPS Plan and changes in transfer pricing.
Yaroslav Romanchuk during the lesson “Implementation of the provisions of the BEPS plan – implications for business” revealed the point and objectives of BEPS, which provides for the improvement of transfer pricing rules, prevention of tax evasion through international agreements, income taxation of controlled foreign companies (CFC) , information exchange, describing 15 steps to overcome capital movements and tax erosion, listed 137 countries in the world that have joined the BEPS plan, talked about the use of a foreign element in corporate business structuring, about the benefits of having a foreign element , as well as the implications of the countries’ implementation of this plan. The expert also noted that today huge financial resources are located in low-tax areas and are not taxed in the countries of residence, according to various data, about 80% of world trade is accounted for by transactions between companies that are part of one group.
In addition, the speaker shared with the participants of the module his own view on the process and consequences of the implementation of the BEPS plan in Ukraine within the law # 1210. Thus, the expert figured out the main points of the law, describing each of these points more detailed.
Yaroslav Romanchuk drew the attention to the topic of offshore, noting that the era of “death” of offshore has already begun, which will now be replaced by new alternative tools. The speaker emphasized that the rules of the game for business have changed since 2015, as offshore companies have ceased to perform their functions under the new legislation, and the disclosure of final beneficiaries has become mandatory. At present, consultants in the EU are required to report to the tax authorities on any proposals for tax planning that may show signs of aggressive planning. In addition, the lecturer considered the launch of automatic exchange of financial and tax information , which should start working in Ukraine soon. In conclusion, the speaker spoke about the reasons of using a foreign element in corporate structuring and whether the EU and Poland, in particular, can become an alternative to offshore.
