The resolution updates the list of states and territories recognized as meeting the criteria for low-tax jurisdictions in accordance with the Tax Code of Ukraine (subsection 39.2.1.2 of Article 39). This list is used for transfer pricing purposes and control of transactions with counterparties from these jurisdictions.
Structurally, the document consists of two parts: the resolution on amendments and an annex with an updated list of states and territories. The resolution takes effect from January 1, 2025.
The list includes 45 jurisdictions, among which are traditional offshore zones (Bahamas, British Virgin Islands, Cayman Islands), as well as some states with special taxation regimes (Iran, North Korea, Myanmar). When conducting business operations with counterparties from these jurisdictions, taxpayers must comply with transfer pricing rules and additional tax control requirements.
