The Protocol to the 1993 income and capital tax treaty between Ukraine the UK was signed on 9 October 2017. The amendments made by the protocol are summarized as follows:
- The preamble is replaced, including new language regarding treaty abuse developed as part of the BEPS project;
- Article 1 (Personal Scope) is replaced, including a provision addressing the treatment of transparent entities;
- Article 2 (Taxes Covered) is amended with respect to the Ukraine taxes covered;
- Article 3 (General Def…