The Ukrainian Parliament Ratified the Protocol Amending the Double Tax Treaty with the Netherlands
17/06/21
On 15 June 2021 Ukraine’s parliament ratified the Protocol amending the Double Tax Treaty between Ukraine and the Netherlands (further – "Protocol").
The Protocol will enter into force after Ukraine and the Netherlands complete ratification procedures. Should it happen this year, the new withholding tax (further – "WHT") rates for payments to the residents of the Netherlands will apply starting from 1 January 2022 and will be as follows:
The Protocol introduces a so-called ‘principle purpose test’ which denies treaty benefits if the main purpose of a transaction is to obtain such treaty benefits. Apart from that, the Protocol amends the definition of tax resident, permanent establishment and enhances the procedures for the elimination of double taxation, mutual support in tax collection and exchange of information between the tax authorities of Ukraine and the Netherlands.
We will continue monitoring the developments in the international tax area and keep you updated.
