On 13 April 2017 the Parliament of Ukraine ratified the Convention between the Government of Ukraine and the Government of the Republic of Malta “On Avoidance of Double taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income” (the “Convention”) and a protocol to it (the “Protocol”). The Convention and the Protocol were signed in Kyiv on 4 September 2013.

The Convention provides for the following rates of taxation of dividends, interest and royalties which are in line with the requirements of the OECD Model Tax Convention:

  • Dividends – 15% or 5%: the reduced tax rate applies if the dividend recipient owns at least 20% of the capital of the dividend paying company.
  • Interest and Royalties – 10%.

The Law on ratification of the Convention and the Protocol are now waiting to be signed by the President of Ukraine.

The Convention shall enter into force following mutual notifications by both states.

The ratification of the Convention and the Protocol will promote the avoidance of double taxation, the prevention of fiscal evasion and the mutual reduction of tax barriers for foreign investment.  

Legislation: Law “On Ratification the Convention between the Government of Ukraine and the Government of the Republic of Malta “On Avoidance of Double taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income”” No. 0141 dated 6 April 2017.