Ukrainian Anti-BEPS Law and Its Impact on Energy Companies


Law No.xn--466--86d6h "On Amendments to the Tax Code of Ukraine Aimed at Improving the Administration of Taxes, and Eliminate Technical and Logical Inconsistencies in the Tax Legislation" (the “Anti-BEPS Law”), which was adopted by the Verkhovna Rada of Ukraine on January 16, 2020, entered into full force and effect on May 23, 2020, after being signed by the President of Ukraine and officially published.

The Anti-BEPS Law is primarily aimed at preventing the shifting of profit from Ukraine to low-tax jurisdictions and restricts unjustified application of tax benefits under international double taxation treaties. Furthermore, the Anti-BEPS Law establishes new tax reporting procedures, procedures for taxation of non-residents in Ukraine, and introduces significant changes to tax administration. 

You can find below at the respective links brief overview of Anti-BEPS Law,


In respect of the energy companies, such companies and their shareholders shall take into account relevant requirements of Anti-BEPS Law while structuring payments via foreign holdings or direct or indirect ownership in shares of Ukrainian companies.