Ukraine: Recent tax changes in Ukraine

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Ukraine: Recent tax changes in Ukraine

kotenko.jpg

kalyta.jpg

Vladimir Kotenko


Iryna Kalyta

New Ukraine-Cyprus Double Tax Treaty starts applying

On January 1 2014, the Ukraine-Cyprus double tax treaty started to apply. The new treaty supersedes the exceptionally beneficial USSR-Cyprus treaty and provides for 5%/15% on dividends, 2% on interest and 5%/10% on royalties. Ukraine and Cyprus also managed to resolve the discrepancy between the Greek and the Ukrainian texts of the Ukraine-Cyprus treaty and ensured that the USSR-Cyprus treaty ceased to apply when the new treaty started applying, and not earlier.

Decrease of corporate profit tax and VAT rate is postponed

Ukraine postponed the declared decrease of corporate profit tax and VAT rates. In 2014, the VAT rate will remain the same as in 2013 (20%), whereas corporate profit tax rate will go down by one percentage point and be 18% (as opposed to the initially declared 16%).

Transfer of shares exempt from transfer tax

Starting in 2014, the transfer of shares in joint stock companies is no longer subject to the special purpose excise tax (which could reach up to 1.5% of the contract value). This legislative development significantly narrows the list of transactions covered by the tax. The exemption was introduced as part of a package of technical changes to the Tax Code of Ukraine, so it is not clear whether it truly was intended by the law maker.

Developments in new Ukrainian transfer pricing rules

The Ukrainian government adopted a list of low-tax jurisdictions that will apply for transfer pricing purposes. Transactions between Ukrainian companies and non-Ukrainian companies resident in low tax jurisdictions will be subject to Ukrainian transfer pricing rules even if these companies are unrelated. The list comprises of 74 states where the corporate profit tax rate is lower than that of Ukraine by 5%, and includes Cyprus, Ireland and Switzerland.

The Ukrainian government has also published a draft transfer pricing reporting template. The template is similar to that used in Russia, and implies disclosure of detailed information on controlled operations.

Vladimir Kotenko (vladimir.kotenko@ua.ey.com) and Iryna Kalyta (iryna.kalyta@ua.ey.com)

EY

Tel: +380 44 490 3000

Fax: +380 44 490 3030

Website: www.ey.com/ua

more across site & shared bottom lb ros

More from across our site

A new focus on early intervention and increased AI use is transforming how tax authorities are approaching TP audits, though capacity-constrained jurisdictions risk falling behind
The French administration has used AI to detect undeclared swimming pools and verandas but always includes a human in the loop, the AI in Tax Forum heard
The UK tax authority’s deputy director of large business also reassured taxpayers that HMRC will not ‘nitpick’ returns
Sucafina’s tax chief was speaking at the ITR Pillar 2 Forum in London alongside experts from HMRC and other organisations
India’s Supreme Court rattled cross‑border structuring with its Tiger Global ruling. Subsequent rule changes narrowed the impact, but significant risks around GAAR, substance and treaty access persist
The UK-based big four spin-off firm has hired Marc Lien, who declared that most AI in professional services today is ‘cosmetic’
Projected revenue losses and exemption requests are harming the project’s capability and viability
HMRC secured lengthy prison sentences in a major payroll VAT fraud case, while law firms announced tax promotions and hires
Significant changes include an update to profit markers and an alteration to how an ‘inbound distributor’ is defined
ITR sat down for a pre-event interview with Tim Zech, WTS Germany, and Jeff Soar, WTS UK, keynote speaker at next week’s ITR AI in Tax Forum 2026 in London
Gift this article