The Ukraine State Fiscal Service has issued Letter No. 12908/7/99-99-15-02-01-17 to clarify the effect of Cabinet Resolution No. 108, which provided for the exclusion of Estonia, Georgia, Hungary, Latvia, and Malta from Ukraine's list of tax havens ({News-2018-03-13/A/7-previous coverage}). The letter clarifies that transactions with these jurisdictions will still be recognized as controlled for transfer pricing purposes in the 2018 tax year if:
- The taxpayer's annual income from any activit…