New list of offshore states and territories

The Ministry of Finance approved a special list of states and territories. The order came into force on April 27, 2024. Its effect was extended to relationships from January 1, 2024. It must be applied to the tax periods 2024 — 2026 for income tax and personal income tax.
The new list includes 40 countries and territories, more than two times less than the list that the Ministry of Finance approved in June 2023. The new list does not include Australia, Canada, the Republic of Cyprus, the United Kingdom of Great Britain and Northern Ireland, the USA, Taiwan (China), Ukraine, or Japan.

The new list must be applied:
  • for tax exemption of profits of controlled foreign companies
  • to adjust the profits of controlled foreign companies
  • to determine the tax base for income tax
  • to apply the dividend profit rate.