The Ukraine government has announced the signing of an amending protocol to the 1996 tax treaty with Denmark on 2 February 2021. The protocol is the first to amend the treaty and includes updates to bring the treaty in line with the latest OECD model. In particular, the protocol:
- Updates the list of taxes covered by the treaty;
- Replaces the 0% withholding tax rate with a 5% rate on royalties for the use of, or the right to use any secret formula or process, or for information (know-how) concerning industrial, commercial, or scientific experience;
- Expands the provisions on the exchange of information and assistance in the collection of taxes; and
- Adds a Limitation on Benefits article including a main purpose test.
The protocol will enter into force after the ratification instruments are exchanged. Further details of the protocol will be published once available.