Protocol to the tax agreement between Turkey and Ukraine

Protocol to the tax agreement between Turkey and Ukraine comes into force

The pending protocol to the 1996 Income and Capital Tax Agreement between Turkey and Ukraine will enter into force on November 30, 2020. The protocol, signed on October 9, 2017, is the first protocol to amend the treaty and include the following changes:

1. Article 2 (Taxes Covered) updated for taxes to be covered for both countries;
2. Article 3 (General Definitions) has been amended to expand (clarify) the provision regarding terms not defined in the treaty;
3. Article 4 (Resident) has been updated to include the state and any political subdivision or local authority in the definition of “resident of a Contracting State”;
4. Article 8 (International transport) amended to include road vehicles in relation to profits from the use, maintenance, or lease of containers in international traffic;
5. The wording of Articles 10 (Dividends), 11 (Interest) and 12 (Royalties) has been changed for clarity, including that the beneficial owner of a Contracting State is entitled to tax rates by agreement, not just the beneficial owner (rates have not changed);
6. Article 15 (Dependent Personal Services) amended to correct a typographical error in the reference to construction or installation work (initially an incorrect subparagraph of Article 5 was mentioned);
7. Article 26 (Exchange of Information) replaced to bring it in line with OECD standards for information exchange;
8. Added new article 26A (Promotion of Tax Collection).
   The protocol comes into force on January 1, 2021.

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