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Regulatory Affairs

25/ 09/ 2013
  As result of active work by the European Business Association (hereinafter – the Association), the Ministry of Internal Affairs of Ukraine (hereinafter – the MIA of Ukraine) considered the Association proposals on the registration of vehicles belonging to the representative offices of foreign legal entities, and prepared the Resolution of the Cabinet of Ministers of Ukraine “On Amendments to the Order of State Registration (Reregistration), Deregistration of Cars, Buses, and Self-Propelled Machines Designed On the Chassis of Cars, Motorcycles of All Types, Makes and Models of Trailers, Semi-Trailers, Sidecars, Others Equal To Them Vehicles and Motorcycles” No. 610 of 1 August 2013 (hereinafter – the Resolution of the Cabinet of Ministers of Ukraine No. 610), which entered into force on 6 September 2013. Background: For a long time the registration of vehicles owned by the representative offices of foreign legal entities in Ukraine was not legally regulated. Such vehicles could not be registered in the registration and examination departments of the State Automobile Inspection of Ukraine. Moreover, they had to be registered in the country of their legal entity and imported into Ukraine under the obligation of re-export. This was because the Order of State Registration (Re-Registration), Deregistration of Cars, Buses, And Self-Propelled Machines Designed on the Chassis of Cars, Motorcycles of All Types, Makes And Models of Trailers, Semi-Trailers, Sidecars, Others Equal To Them Vehicles and Motorcycles, approved by the Cabinet of Ministers of Ukraine No. 1388 of 7 September 1998 (hereinafter - the Resolution of the Cabinet of Ministers No.1388), determined the procedure of vehicle registration for legal entities and individuals. However, in accordance with paragraph 3 of Article 95 of the Civil Code of Ukraine No. 435-IV dated 16 January 2003 branch offices and representative offices are not legal entities .... In this connection the legal gap appeared. The Association, for its part, has made significant efforts to improve the legislation on the registration of vehicles belonging to the representative offices of foreign legal entities in Ukraine, but without legal status.  We repeatedly appealed to MIA of Ukraine with the proposals developed by our member companies. On 1 August 2013 the Cabinet of Ministers of Ukraine adopted the Resolution of the Cabinet of Ministers No. 610, which amends the Resolution of the Cabinet of Ministers of Ukraine No. 1388. According to these amendments, the registration of vehicles belonging to the representative offices of foreign legal entities in Ukraine will be conducted based on the general principles of the Resolution of the Cabinet of Ministers of Ukraine No. 1388 (abstract 3 of paragraph 12). We are pleased to inform you that on 6 September the Resolution from the Cabinet of Ministers of Ukraine No. 610 came into force and the above issue was legally settled. The Association expresses its appreciation to the Ukrainian government, the relevant ministries for their constructive dialogue and fruitful cooperation, as well as all member companies of the Association for your participation and persistence in solving this problem. We will continue to work to resolve problematic issues in order to protect the legitimate interests of our members.



As result of active work by the European Business Association (hereinafter – the Association), the Ministry of Internal Affairs of Ukraine (hereinafter – the MIA of Ukraine) considered the Association proposals on the registration of vehicles belonging to the representative offices of foreign legal entities, and prepared the Resolution of the Cabinet of Ministers of Ukraine “On Amendments to the Order of State Registration (Reregistration), Deregistration of Cars, Buses, and Self-Propelled Machines Designed On the Chassis of Cars, Motorcycles of All Types, Makes and Models of Trailers, Semi-Trailers, Sidecars, Others Equal To Them Vehicles and Motorcycles” No. 610 of 1 August 2013 (hereinafter – the Resolution of the Cabinet of Ministers of Ukraine No. 610), which entered into force on 6 September 2013.


Background: For a long time the registration of vehicles owned by the representative offices of foreign legal entities in Ukraine was not legally regulated. Such vehicles could not be registered in the registration and examination departments of the State Automobile Inspection of Ukraine. Moreover, they had to be registered in the country of their legal entity and imported into Ukraine under the obligation of re-export.


This was because the Order of State Registration (Re-Registration), Deregistration of Cars, Buses, And Self-Propelled Machines Designed on the Chassis of Cars, Motorcycles of All Types, Makes And Models of Trailers, Semi-Trailers, Sidecars, Others Equal To Them Vehicles and Motorcycles, approved by the Cabinet of Ministers of Ukraine No. 1388 of 7 September 1998 (hereinafter – the Resolution of the Cabinet of Ministers No.1388), determined the procedure of vehicle registration for legal entities and individuals. However, in accordance with paragraph 3 of Article 95 of the Civil Code of Ukraine No. 435-IV dated 16 January 2003 “branch offices and representative offices are not legal entities …”. In this connection the legal gap appeared.


The Association, for its part, has made significant efforts to improve the legislation on the registration of vehicles belonging to the representative offices of foreign legal entities in Ukraine, but without legal status.  We repeatedly appealed to MIA of Ukraine with the proposals developed by our member companies.


On 1 August 2013 the Cabinet of Ministers of Ukraine adopted the Resolution of the Cabinet of Ministers No. 610, which amends the Resolution of the Cabinet of Ministers of Ukraine No. 1388. According to these amendments, the registration of vehicles belonging to the representative offices of foreign legal entities in Ukraine will be conducted based on the general principles of the Resolution of the Cabinet of Ministers of Ukraine No. 1388 (abstract 3 of paragraph 12).


We are pleased to inform you that on 6 September the Resolution from the Cabinet of Ministers of Ukraine No. 610 came into force and the above issue was legally settled.


The Association expresses its appreciation to the Ukrainian government, the relevant ministries for their constructive dialogue and fruitful cooperation, as well as all member companies of the Association for your participation and persistence in solving this problem. We will continue to work to resolve problematic issues in order to protect the legitimate interests of our members.

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