Ukraine's Ministry of Finance has published the synthesized texts of the tax treaties with Japan, Luxembourg, Poland, Serbia, and the Slovak Republic as impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The synthesized texts were prepared on the basis of the reservations and notifications submitted to the Depositary by the respective countries. The authentic legal texts of the treaty and the MLI take precedence and remain the legal texts applicable.
The MLI applies for the 1986 Ukraine-Japan tax treaty:
- with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2020; and
- with respect to all other taxes, for taxes levied with respect to taxable periods beginning on or after 1 June 2020.
The MLI applies for the 1997 Ukraine-Luxembourg tax treaty:
- with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2020; and
- with respect to all other taxes, for taxes levied with respect to taxable periods beginning on or after 1 June 2020.
The MLI applies for the 1993 Ukraine-Poland tax treaty:
- with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2020; and
- with respect to all other taxes, for taxes levied with respect to taxable periods beginning on or after 1 June 2020.
The MLI applies for the 2001 Ukraine-Serbia tax treaty:
- with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2020; and
- with respect to all other taxes, for taxes levied with respect to taxable periods beginning on or after 1 June 2020.
The MLI applies for the 1996 Ukraine-Slovak Republic tax treaty:
- with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2020; and
- with respect to all other taxes, for taxes levied with respect to taxable periods beginning on or after 1 June 2020.
MLI synthesized texts of Ukraine's tax treaties can be found on the Ministry of Finance's MLI webpage.