The Ukrainian Ministry of Finance has released an updated version of its tax treaty with Cyprus, which includes changes implemented through the Multilateral Convention (MLI) to combat tax base erosion and profit shifting (BEPS).
The MLI is an international agreement that allows countries to modify existing tax treaties simultaneously, aiming to close gaps exploited by multinational corporations to minimise their tax burdens.
This update clarifies how the MLI affects the 2012 Ukraine-Cyprus tax treaty, particularly regarding withholding taxes on payments to non-residents. These changes apply retroactively to 1 January 2021 for withholding taxes and to taxable periods beginning on or after 1 November 2020 for all other taxes.
The Ministry emphasised that the original treaty and the MLI itself remain legally binding documents. This synthesised text is based on the reservations and notifications provided by each country to the Depositary.
