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Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.


Taxes Covered

(1) This Convention shall apply to taxes on income and on capital imposed on behalf of a Contracting State or of its political sub-divisions or focal authorities, irrespective of the manner in which they are levied.

(2) There shall be regarded as taxes on income and on capital all taxes imposed on total income, on total capital, or on elements of income or of capital including taxes on gains from the alienation of movable or immovable properly and taxes on the total amounts of wages or salaries paid by enterprises, as well as taxes on capital appreciation.

(3) The existing taxes to which this Convention shall apply are in particular:

  • (a) In Ukraine:
    • (i) the profits tax of enterprise;
    • (ii) the individual income-tax;
    • (iii) tax on property of enterprises;
    • (iv) tax on immovable property of citizens;
  • (hereinafter referred to as "Ukrainian tax")
  • (b) In India:
    • (i) the income-tax, including any surcharge thereon;
    • (ii) the wealth-tax;
  • (hereinafter referred to as "Indian tax").

(4) This Convention shall also apply to any identical or substantially similar taxes which are imposed by either Contracting State after the date of signature of this Convention in addition to, or in place of the existing taxes. The competent authorities of the Contracting States shall notify each other of any substantial changes which are made in their respective taxation laws.