On February 2, 2021, Minister of Finance Sergii Marchenko signed the Protocol on Amendments to the Convention between the Government of Ukraine and Government of the Kingdom of Denmark on the avoidance of double taxation and prevention of fiscal evasion regarding income and property taxes (hereinafter - the Convention).
This Protocol introduces amendments to the Convention in order to bring its provisions in line with the OECD Model Tax Convention.
In particular, the Protocol provides for:
- updating the list of taxes covered by the Convention;
- abolishing zero royalty rate in the country in which they occur (tax rate increased to 5%);
- enhancing the ability of tax authorities of Ukraine and Denmark to exchange tax information and amending the article on assistance in taxation;
- supplementing the Convention with the article "Right to Benefits", which limits the application of the Convention's preferential provisions, in case the main purpose is to obtain such benefits.
The subjects of the implementation of the Protocol are the Ministry of Finance of Ukraine and the State Tax Service of Ukraine.