Ukraine and the United Arab Emirates Signed a Protocol Amending the Double Tax Treaty
18/02/21
On 14 February 2021 the representatives of Ukraine and the United Arab Emirates ("UAE") signed a Protocol amending the Double Tax Treaty between two countries ("DTT" and "Protocol" accordingly).
The Protocol will enter into force after Ukraine and the UAE complete ratification procedures. Should it 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 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.
