The protocol to the 1997 income and capital tax treaty between Luxembourg and Ukraine was signed on 30 September 2016. The protocol makes the following main changes: Paragraph 3 of Article 5 (Permanent Establishment) is replaced to include that a permanent establishment will be deemed constituted when an enterprise furnishes services in a Contracting State through employees or other engaged personnel for the same or connected project for a period or periods aggregating more than 6 months within any 12-month period; Paragraph 3 of Article 10 (Dividends) is deleted, which removes the withholding tax exemption where the beneficial owner of...