Increased withholding tax rates in the instances of application of the Convention between the Government of Ukraine and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation

On 9 October 2017, the Government of Ukraine and the Government of the United Kingdom of Great Britain and Northern Ireland signed the Protocol for introduction of amendments into the Convention between the Government of Ukraine and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation (hereinafter referred to as the “Protocol”). The Protocol signed between Ukraine and the United Kingdom of Great Britain and Northern Ireland provides for the following:

  • Rate of the tax chargeable on dividends, amounting to 5%, if actual payer of dividends is a company (other than partnership), which directly owns at least 20% of capital in the company paying such dividends. In all other instances, the rate was increased from 10% up to 15%
  • Increased rate of the tax chargeable on interests – from 0% up to 5%
  • Increased rate of the tax chargeable on royalties – from 0% up to 5%
  • Re-stated version of the article regarding shared information, whereby the Contracting States’ options for sharing the tax-related information are considerably broadened.

Extension of the definition “resident” and broadened options for sharing the tax-related information in the instances of application of the Convention between the Government of Ukraine and the Government of Turkey for the Avoidance of Double Taxation

On 9 October 2017, the Government of Ukraine and the Government of Turkey signed the Protocol for introduction of amendments into the Convention between the Government of Ukraine and the Government of Turkey for the Avoidance of Double Taxation (hereinafter referred to as the “Protocol”). The Protocol signed between Ukraine and Turkey provides for the following:

  • Extension of the notion “resident” in compliance with the provisions of the Model Convention of OECD
  • Re-stated version of the article regarding shared information, whereby the Contracting States’ options for sharing the tax-related information are considerably broadened and reservations are excluded in connection with requirements regarding the national taxation-related interests or bank secrets
  • New article related to the assistance in collection of taxes, whereby the Contracting States shall render assistance to each other in collection of tax debts.

Negotiations are conducted in connection with introduction of amendments into the Convention between the Government of Ukraine and the Government of the Swiss Confederation for the Avoidance of Double Taxation and the Prevention of Tax Evasion

The issue of bilateral cooperation between Ukraine and Switzerland was discussed during the working visit to Washington on 12 October. One of the key issues raised during the meeting was introduction of amendments into the Convention between the Government of Ukraine and the Government of the Swiss Confederation for the Avoidance of Double Taxation and the Prevention of Tax Evasion. The parties agreed to finalize the document in the nearest future and sign the Protocol for the introduction of the respective amendments.