What levy rate for the one-time (special) voluntary declaration is applied to the nominal value of government bonds of Ukraine with a maturity of more than 365 days without early redemption, which were purchased after 01.09.2021 at the expense of funds fr

Sub-paragraph “c” Paragraph 4 Sub-section 9⁴ Section “Transitional Provisions” of the Tax Code of Ukraine as of 02.12.2010 № 2755-VI with changes and amendments (hereinafter – TCU) stipulates that objects of the one-time (special) voluntary declaration  may be individual’s assets, defined in Sub-paragraph 14.1.280 and 14.1.281 Paragraph 14.1 Article 14 of the TCU, owned by the declarant (including joint partial or joint common ownership right) and are (registered, in circulation, registered, etc.) on the territory of Ukraine and / or abroad as of the date of submission of the one-time (special) voluntary declaration (hereinafter – Declaration), in particular, movable property, including other valuable movable property (objects of art and antiques, precious metals, precious stones, jewelry, etc.).

Sub-paragraph 5.5 Paragraph 2 Article 8 of the Law of Ukraine as of 23.02.2006 № 3480-IV “On capital markets and organized commodity markets” with changes and amendments (hereinafter – Law № 3480) stipulates that government bonds of Ukraine belong to securities.

Paragraph 2 Article 16 of the Law № 3480 prescribes that government bonds of Ukraine are divided into bonds of domestic government loans of Ukraine and bonds of external government loans of Ukraine.

Ukraine’s external government bonds are securities placed on international capital markets and confirm Ukraine’s obligation to reimburse the nominal value to holders of these bonds with payment of income according to terms of the bonds placement (Paragraph 4 of Article 16 of Law № 3480).

Sub-paragraph 8.3 Paragraph 8 Sub-section 9⁴ Section XX “Transitional provisions” of the TCU establishes rate of levy for the one-time (special) voluntary declaration (hereinafter – levy) is set at 2.5% on the nominal value of government bonds of Ukraine with a maturity of more than 365 days without the early redemption, purchased by the declarant in a period from September 1, 2021 to August 31, 2022 before submitting the one-time (special) voluntary declaration (alternatively, the taxpayer may choose 3% rate with payment of tax liability in three equal parts annually).

9% rate is applied to declaration objects, in particular securities that are (registered) abroad, except for those that are taxed at rate specified in Sub-paragraph 8.3 Paragraph 8 Sub-section 9⁴ Section XX “Transitional Provisions” of the TCU (Sub-paragraph 8.2 Paragraph 8 Sub-section 9⁴ Section XX “Transitional Provisions” of the TCU).

As follows, 2.5% rate is applied to the one-time (special) voluntary declaration on the nominal value of government bonds of Ukraine with a maturity of more than 365 days without the early redemption, purchased by individual after 01.09.2021 to 31.08.2022 at the expense of funds from which taxes were not paid and which are placed in foreign financial institutions.

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