Ukraina zaktualizowała listę krajów, z którymi ma umowy o unikaniu podwójnego opodatkowania: co się zmieniło?

Ukraina zmieniła listę krajów, z którymi ma umowy o unikaniu podwójnego opodatkowania. Dowiedz się, z którymi krajami umowy pozostają w mocy, które kraje zostały wykluczone i jak wpłynie to na przedsiębiorstwa i obywateli

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On June 6, 2025, Law No. 4278-IX was published in Holos Ukrainy, updating the list of Ukraine's international agreements on the avoidance of double taxation. It came into force on June 7. This is the final stage of a large-scale initiative launched back in November 2024, when President Volodymyr Zelensky registered draft law No. 0293 in the Verkhovna Rada. It was adopted in its entirety on February 27, 2025, and signed on June 4.

The changes are to Article 1 of the Law of Ukraine “On the Ratification of the Multilateral Convention on the Implementation of Measures Concerning Tax Agreements to Prevent Base Erosion and Profit Shifting.” The amendments are part of the international BEPS (Base Erosion and Profit Shifting) initiative supported by the Organization for Economic Cooperation and Development (OECD).

Who is excluded: countries with which double taxation agreements are no longer in force

According to the updates, Ukraine no longer extends the Convention on the Avoidance of Double Taxation to the following countries:

● russian federation

● Belarus

● Syria

● Cuba

This means that previous agreements on the avoidance of double taxation with these countries have expired or have not entered into force due to the lack of ratification. The explanatory note to the law states that Cuba, in particular, was excluded from the list because the Cuban side had not completed the internal procedures necessary for the ratification of the Convention.

This step is logical and politically motivated, given the change in the vector of Ukraine's international cooperation, as well as to avoid abuse by countries that do not ensure an adequate level of transparency or do not cooperate in the field of tax exchange.

With whom double taxation agreements have entered into force or been updated

Instead, Ukraine has either updated or signed new agreements with many partner countries that meet current international standards. These include:

● Austria

● Denmark

● Netherlands

● United Kingdom

● Switzerland

● Singapore

● UAE

● Malaysia (new agreement)

● Qatar

These agreements provide for updated mechanisms to prevent tax evasion, transparency in the exchange of information, and other provisions in line with the BEPS initiative. For businesses, this means reduced tax risks in cross-border activities, and for the state, it means strengthening fiscal discipline and preventing budget losses.

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Updated list of partner countries with which double taxation agreements are in force

Ukraine has double taxation agreements with more than 70 countries around the world, including:

Why are these changes important for entrepreneurs and investors?

Double taxation agreements are the basis for predictable taxation for Ukrainians working outside Ukraine and foreigners working or doing business in Ukraine. The existence of such an agreement means that:

● taxes are not levied twice – both in Ukraine and in the partner country;

● the overall tax burden is reduced;

● there is a clear legal mechanism for resolving tax disputes;

● transparency and exchange of information between the tax authorities of both countries is ensured.

Since international taxation often raises questions for individuals, sole proprietors, and companies, it is important to obtain professional legal support. Visit Ukraine lawyers provide advice on tax residency, business registration abroad and in Ukraine, income legalization, and the correct application of double taxation agreements. This is especially useful if you work remotely, receive foreign payments, or plan to scale your business to international markets.

We remind you! In 2025, Ukraine will offer a wide range of tax incentives for foreign investors. Read about the incentives available and how to use them effectively in our previous article.

Want to know more? Read the latest news and useful materials about Ukraine and the world in the News section.

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