Emerging Markets Rates and Currencies Handbook

Tax Summary – Ukraine Ukraine accrued to non- resident-banks or to international financial institutions • • The non- deductible portion of interest can be carried forward indefinitely. However, each following year the residual amount of such interest should be reduced by 5% Deductibility of (FX) Losses • Both realized and unrealized FX losses are tax-deductible Other Taxes/Duties • It is not currently possible to register a branch of a foreign legal entity in Ukraine. A foreign company may set up a representative office instead. • Derivatives are not subject to VAT * For the purposes of thin capitalization rules, debt includes any loan, deposit, repo transactions, financial leasing, and any other debenture, regardless of its legal form. Note: Citigroup Inc. and any of its affiliates do not provide accounting, tax, or legal advice. Please seek advice from a relevant licensed advisor. Source: Relevant legislation, publicly available sources Country Deductibility and Considerations Inter-Co Debt Offshore Bank Loans Offshore Local Borrowing Derivatives Equities