The Ukrainian Parliament Ratified the Protocol Amending the Double Tax Treaty with the United Arab Emirates

On 8 September 2021 Ukraine’s parliament ratified the Protocol amending the Double Tax Treaty between Ukraine and the United Arab Emirates ("Protocol" and "DTT" accordingly).

The Protocol will enter into force after Ukraine and the United Arab Emirates ("UAE") complete the ratification procedures. Should that happen this year, from 1 January 2022 the withholding tax (“WHT”) rates for payments made to tax residents of the UAE will change as follows:

The Protocol also includes the ‘principal purpose test’, which enables the tax authorities to deny treaty benefits (e.g. reduced WHT rates) if the main purpose of a transaction is to obtain such treaty benefits (even though this modification to the DTT is already introduced by the MLI). Apart from that, the Protocol amends the taxation of dividends and profits from international shipping and air transport activities, as well as enhances the procedure for the exchange of information between the UAE and Ukrainian tax authorities.

We will continue monitoring the developments in the international tax area and keep you updated.