The new tax treaty replaces the 1986 tax treaty between Japan and Ukraine.
Japan’s Ministry of Finance announced on 2 July 2025 that the new income tax treaty between Japan and Ukraine entered into force on 1 August 2025.
The new treaty, signed on 19 February 2024, aims to eliminate double taxation and prevent tax evasion between the two countries.
For Japan, it covers income tax, corporation tax, special income tax for reconstruction, local corporation tax, and local inhabitant taxes. For Ukraine, it applies to individual income tax and tax on enterprise profits.
Concerning withholding tax rates, dividends are taxed at 5% for companies that own at least 25% of the payer for more than 6 months; otherwise, the tax rate is 15%. Interest is 10% generally, 5% for financial institutions, and exempt for states, central banks, or guaranteed debts. Royalties are taxed at 5%.
In Japan, the treaty applies from 1 January 2026 for taxes based on a taxable year, as well as for taxes not based on a taxable year. In Ukraine, it applies from 1 January 2026 for withholding taxes and for other taxes from taxable periods starting on or after 1 January 2026.
The new treaty replaces the 1986 tax treaty between Japan and the former Soviet Union, which will no longer apply to Japan and Ukraine from that date.
Earlier, Japan’s Ministry of Finance announced on 2 July 2025 that the 2024 tax treaty and protocol with Ukraine will come into effect on 1 August 2025.
