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

The latest edition of Taxing Times with ITR covers all the controversy from a dramatic period for the carve-out deal, and also dissects the big four's AI strategies
Hany Elnaggar examines how the OECD’s global minimum tax is reshaping PE concepts across the GCC, shifting the focus from formal presence to substantive economic activity
The combination between Ashurst and Perkins Coie, which will create a $2.8 bn law firm, is expected to close in Q3
The ‘highly regarded’ Stephanie Pantelidaki, who has big four experience, will be based in the firm’s London office
A co-operative working relationship with the UK tax agency has helped 'unblock entrenched positions' to the benefit of clients, Kara Heggs tells ITR
New hires from rivals are reportedly being axed from the firm, following a steep decline in profits
Following Richard Houston’s switch to the newly formed Deloitte EMEA, Graves has the opportunity to bring Deloitte’s tax practice up to speed with its rivals
Firms announced tax hires and promotions across Europe and the US, while fresh figures from Ireland showed corporation tax receipts edging down in the first quarter
The country has overseen better audit procedures and demonstrated commitment to acting as a 'regional leader' on international tax matters, the OECD said
Barrister Setu Kamal and policy guru Dan Neidle have clashed over the former’s legal action against Google, described as ‘bonkers’ by Neidle
Gift this article