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Protocol to Tax Treaty between Ukraine and the UK in Force

16 January 2020

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Treaty Development

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Ukraine-United Kingdom

The Protocol to the 1993 income and capital tax treaty between Ukraine the UK entered into force on 5 December 2019. The protocol, signed 9 October 2017, is the first to amend the treaty and includes the following changes: The preamble is replaced, including new language regarding treaty abuse developed as part of the BEPS project; Article 1 (Personal Scope) is replaced, including a provision addressing the treatment of transparent entities; Article 2 (Taxes Covered) is amended with respect to the Ukraine taxes covered; Article 3 (General Definitions) is amended with respect to a number of terms, including the meaning...