The governments of the UK and Ukraine signed a protocol on 9 October 2017 to amend the 1993 double taxation convention between the two countries. The new protocol has not yet entered into force.
The protocol will increase the permitted taxation rates on dividends to 15% (from 10%) and on interest and royalties to 5% (from 0%). The protocol also replaces the existing residency tie-breaker for non-individuals with a competent authority-based approach; introduces a principal purpose test; and amends the mutual agreement procedure provisions to bring them in line with the OECD’s BEPS minimum standards. See here.
The governments of the UK and Ukraine signed a protocol on 9 October 2017 to amend the 1993 double taxation convention between the two countries. The new protocol has not yet entered into force.
The protocol will increase the permitted taxation rates on dividends to 15% (from 10%) and on interest and royalties to 5% (from 0%). The protocol also replaces the existing residency tie-breaker for non-individuals with a competent authority-based approach; introduces a principal purpose test; and amends the mutual agreement procedure provisions to bring them in line with the OECD’s BEPS minimum standards. See here.
