Ukraine’s Parliament Ratified the Protocol Amending the Double Tax Treaty with Austria
17/12/20
On 16 December 2020 Ukraine’s Parliament ratified the Protocol amending the Double Tax Treaty between Ukraine and Austria (further – "Protocol").
The Protocol has been already ratified by the Austrian side. Only some formal procedures, including the exchange of ratification letters between the countries, are left to be done. Thus, we expect the Protocol to enter into force soon. Still, as prescribed by the Protocol, the new withholding tax (further – "WHT") rates for payments to Austrian residents will apply only from 1 January 2022 ( from 1 January 2023 for royalty) and will be as follows:
The Protocol also introduces a so-called ‘principle purpose test’ which denies treaty benefits if the main purpose of a transaction is to obtain such treaty benefits. The Protocol also introduces amendments aimed at enhancing the exchange of information between the Austrian and Ukrainian tax authorities.
We will continue monitoring the developments in the international tax area and keep you updated.
