|Vladimir Kotenko||Iryna Kalyta|
Ukrainian tax authorities question beneficial ownership status of non-resident royalty recipients
Ukrainian tax authorities started to actively question the beneficial ownership status of non-resident royalty recipients. IP sublicensing structures are under the biggest scrutiny. Several treaty shopping allegations have been known to be raised. No conclusive court practice has formed as yet.
Double tax treaty between the government of Ukraine and the government of Saudi Arabia came into force
A double tax treaty between Ukraine and Saudi Arabia started applying in 2013. The treaty provides the following key withholding tax rates:
- Dividends: 5% / 15%
- Income from debt-claims: 10%
- Royalty: 10%
Tax exemption applies for dividends, interest and royalties received by the government.