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

Brazil's tax system is being reshaped by VAT , pillar two and TP reform. Fallet explains why those changes convinced him to lead a new practice
The agreement with Daribatech, alongside recent high-profile investment in talent, suggests the firm is gearing up for a significant push in the region
Several factors have led to a steady transition of TP work away from traditional advisers and towards full-service law firms, DLA Piper’s new TP leader says
Julian Balson's departure from EY's Tier 1 tax controversy practice for lower-ranked Fieldfisher represents one of the more eye-catching UK hires of the year
Former IRS commissioner Danny Werfel argues that the biggest obstacle to AI adoption in tax is not technology, but trust, and introduces a practical AI risk framework to help
Howell takes a deep dive into how he led the landmark PepsiCo dispute, discusses the ATO's enforcement priorities, and emphasises KordaMentha's market ambitions
Global tax leader David Linke said that the TaxSim gaming programme could replace aspects of traditional face-to-face learning
Former ATO economist Craig Silverwood is joining from Australian firm MinterEllison
The rebranding, which will see changes to signage, visual identity and digital properties, is scheduled to be completed by the end of this year
The software space was previously more fragmented, but that model is becoming more difficult to sustain as tax administration becomes increasingly digitised
Gift this article