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Update - Protocol to Tax Treaty between Ukraine and the UK

08 November 2017

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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 was signed on 9 October 2017. The amendments made by the protocol are summarized as follows: 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 of "United Kingdom", "Ukraine", "competent authority", and others; Article...