Cyprus - Ukraine Double Tax Treaty

The protocol to the Cyprus – Ukrainian double tax treaty which was signed in 2015 was enacted into law by Ukraine on 30 October 2019 and shall have effect on 1st  January 2020.


The main provisions of the protocol are as follows: -


  • Dividends – a 5% withholding tax will be levied if the dividends are paid out to a foreign company which holds at least 20% of the share capital of the company paying the dividends and has invested at least €100.000 in the acquisition of the shares or other rights of the company. In all other cases the withholding tax will be 10%.
  • Interest – a 5% withholding tax will be levied on interest payments (currently 2%)
  • Capital gains – the gains derived by a resident of a contracting state from the alienation of shares or interest in the capital of a company which derives more than 50% of their value directly or indirectly from immovable property situated in that other contracting state, maybe taxed in that other contracting state with some exceptions. Any other share disposals are taxed in the state of the alienator provided they are subject to tax in that state.

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