The Ukraine State Fiscal Service recently issued a guidance letter concerning the application of the 2000 income and capital tax treaty with Switzerland as amended by the 2019 protocol. In particular, the letter addresses a question from a Ukraine resident regarding withholding tax on interest and royalty income that was calculated in 2020 and paid to a Swiss resident in 2021.
The letter clarifies that in respect of taxes withheld at source, the changes made by the protocol apply for amounts…