Clients with operations or sales in Ukraine should be aware that recent amendments to the Ukrainian Corporate Profits Tax Law provide that withholding tax rates on passive income and some types of active income of foreign legal entities cannot be reduced by application of double tax treaties. Types of income affected include income from portfolio investment in interest bearing and discounted bonds and treasury bills, revenue from freight, from reinsurance and insurance premiums, advertising activities and dividends. The new amendments appear to contradict Article 18.1 of the Corporate Profits Tax Law which states that international double tax treaties prevail over domestic legislation, which leaves uncertainty as to the actual application of the new approach. Further information or advice may be obtained from Vladimir Didenko at our Kiev office at 380 44 247 6777, or through your normal contact in our Moscow or St Petersburg offices.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
For further information contact Alla Shaulina on tel: +7 503 232 5511 fax: +7 503 232 5522 or e-mail directly: Alla_Shaulina@ru.coopers.com
