On 9 October 2017, the Minister of Finance of Ukraine and the UK Minister of State for Europe and the Americas signed the Protocol on amendments to the Agreement on the Avoidance of Double Taxation between Ukraine and the United Kingdom (the “Protocol”).  The Protocol reportedly revisits the applicable withholding tax rates on core types of passive income, namely:

  • increasing the tax rate on interest from 0% to 5%;
  • increasing the tax rate on royalty from 0% to 5%;
  • confirming the lower tax rate of 5% on dividends received by a legal person (other than a partnership) that directly owns at least 20% of the capital of the paying company (while increasing the higher rate from 10% to 15% when this threshold is not met).

The Protocol is also meant to significantly amend the information-exchange clause to broaden the possibilities to exchange fiscal information between the Parties.

Ukraine and the United Kingdom are yet to conduct all the necessary domestic procedures to ratify the Protocol and the date of entry into force has not been scheduled. Source:

Press Release by Ministry of Finance of Ukraine from 9 October 2017 at https://www.minfin.gov.ua/en/news/view/ukraina-ta--spoluchene-korolivstvo-velykoi-brytanii-i-pivnichnoi-irlandii--pidpysaly-protokol-pro-vnesennia-zmin-do-uhody-pro-unyknennia-podviinoho-opodatkuvannia?category=dohidna-politika&subcategory=podatki (in English)