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Ukraine's double tax treaty with Ireland


Ukraine has completed ratification procedures for a Double Tax Treaty with Ireland. Taxand Ukraine takes a look at the key features.

Withholding tax 'WHT' rates under the Treaty are as follows:

  • Dividends (5% and 15% WHT). Reduced treaty rate of 5% applies if the recipient of dividends is the company, which holds directly at least 25% of the capital of the company paying the dividends. Otherwise, 15% rate applies
  • Interest (0%, 5% and 10% WHT). 0% WHT applies to loans granted by or to the government or its agencies. Reduced treaty rate of 5% applies to loans granted by banks or interest paid in connection with sale on credit of the equipment. Otherwise, 10% rate applies
  • Royalties (5% and 10% WHT). Reduced treaty rate of 5% applies to royalty paid for use of copyrights of scientific work, patent, trademark and know-how. Otherwise, 10% rate applies

Discover more: Ukraine ratifies double tax treaty with Ireland

Your contacts for further queries are:

Roman Stepanenko
T. +38 044 492 8282

Martin Phelan
T. +353 1 639 5138

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Taxand's Take

The Treaty is subject to ratification in both states before it comes into force. If each Ireland and Ukraine finalise exchange of diplomatic notifications of ratification by the end of 2015, the treaty will apply from 1 January 2016.

Taxand's Take Author

Roman Stepanenko

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