Switzerland and Ukraine - amendments to the agreement on avoidance of double taxation

On January 24^th, 2019, Ukraine and the Confederation of Switzerland signed the Protocol on amendments to the agreement on avoidance of double taxation dated 30.10.2000. The Signed Protocol establishes, in particular, an increase in the rate of tax on repatriation of income in the form of interest and royalties (from 0% to 5%), as well as the introduction of the rules of verification of the main purpose (Principal Purpose Test), which are the new standard of double taxation treaties developed under the OECD project.

Under the new standards of the rules, public authorities may refuse to grant tax advantages to one of the Contracting States if they have good reason to believe that the direct or indirect receipt of the tax benefits provided for in the Treaty was one of the main purposes of the use of this agreement.

On materials of the following website: https://zakon.rada.gov.ua/cgi-bin/laws/main.cgi?nreg=756_012