BEPS, MLI, PPT, ATAD, CFC, CbCR, CRS and other tax-related
abbreviations have come into permanent use by the tax authorities,
taxpayers and tax advisors. Although neither of them is currently
applicable in Ukraine important steps have been taken in this
regard in 2018. This article will provide a snapshot of Ukrainian
tax environment as far as international taxation is concerned.
DTT network
Ukraine has a network of 77 double tax treaties (DTTs). Certain
DTTs provide for nil withholding tax
("WHT") rate with respect to income that
would otherwise be subject to a standard Ukrainian WHT of 15%,
provided that the relevant conditions are met. Such income includes
dividends payable to Dutch shareholders, interest payable to UK
creditors, royalties payable to Swiss licensors, capital gains
derived from sale of shares in Ukrainian real property rich
companies payable to Cypriot shareholders, etc.