L&M Finance Group

PARLIAMENT OF UKRAINE RATIFIED AMENDMENTS TO DOUBLE TAXATION TREATIES WITH UK AND CYPRUS

The decision to ratify the amendments to the Treaty for the avoidance of double taxation with the UK and Cyprus was adopted on October 30, 2019. Our lawyers puzzled out the innovations.
Cyprus
Changes to the treaty with this country include:
  • reduction of the maximum dividend rate in the country of residence of the payer - from 15% to 10%;
  • tightening the conditions for applying the minimum rate of 5% for dividends. This rate will be applied if the actual recipient of dividends is a company that owns at least 20% of the capital of the company that pays the dividends and (earlier - or) invested at least 100,000 euros in the acquisition of such capital;
  • refinement of the provisions regarding the sale of movable property (Article 13 of the treaty).
United Kingdom
The main changes are the following:
  • increase in the maximum dividend rate in the country of residence of the payer - from 10% to 15%;
  • interests will be taxed at a rate of 5% in the state in which they occur (now they are taxed only in the state the resident of which receives them);
  • royalties will be taxed at a rate of 5% in the state in which they occur (now taxed only in the state, the resident of which receives them).
The deputies also ratified the Convention on the avoidance of double taxation with Malaysia, the full text of which can be found at: http://w1.c1.rada.gov.ua/pls/zweb2/webproc4_1?pf3511=66774.