The Protocol amending the Ukraine-Cyprus Double Tax Treaty entered into force
PwC Ukraine, Kyiv, Ukraine,
Mon, Dec 16, 2019
Ukraine and Cyprus have finished all procedures required for the Protocol amending the Double Tax Treaty between Ukraine and Cyprus (further – Protocol) to enter into force. Thus, starting from 1 January 2020, the following withholding tax (further – WHT) rates are in effect:
In addition, according to the Protocol, capital gains received by a Cypriot resident may be exempt from Ukrainian WHT if such capital gains are subject to tax in Cyprus. Since capital gains from the disposal of corporate rights are generally exempt from taxation in Cyprus, the enacted changes in the double tax treaty may trigger Ukrainian WHT on any capital gains received by Cypriot residents upon the disposal of corporate rights in Ukrainian companies.