Government Approved Ratification of Protocol Amending Convention between Ukraine and Denmark on the Avoidance of Double Taxation

Today, on September 1, the Cabinet of Ministers of Ukraine adopted the Resolution on submission of the Protocol on Amendments to the Convention between the Government of Ukraine and the Government of the Kingdom of Denmark on the avoidance of double taxation and prevention of fiscal evasion regarding income and property taxes for ratification by the Parliament of Ukraine.

This Protocol amends the Convention to bring its provisions in line with the OECD Model Tax Convention.

In particular, the Protocol provides for:

• updating the list of taxes covered by the Convention;
• canceling the zero rate taxation of royalties in the country of origin;
• amending the article on assistance in the collection of taxes;
• a new version of the article on exchange of information, which provides for a significant increase in the ability of the competent authorities of the Contracting States to exchange tax information;
• an addition to the Convention of the article "Entitlement to benefits".

It restricts the application of the preferential provisions of the Convention if the main purpose of any transaction is to obtain such benefits.

The responsibility of the implementation of the Protocol is on the Ministry of Finance of Ukraine and the State Tax Service of Ukraine.

In addition

The Ministry of Finance has consistently pursued a policy of revising Ukraine's existing international double taxation treaties. The purpose of this work is to bring already existing treaties in line with the standards of the OECD Model Tax Convention.

As of today:

- Protocols amending international treaties with Switzerland, Great Britain, Cyprus, Turkey, Singapore, Austria, and the Netherlands have entered into force;

- the Agreement on Avoidance of Double Taxation with Malaysia has been ratified by the Parliament of Ukraine;

- the international agreements with Spain and the UAE are being prepared for ratification.