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HMRC internal manual

Double Taxation Relief Manual

Ukraine: Previous agreement

Until August 1991, Ukraine was part of the Soviet Union and, as such, was covered by the provisions of both the UK/Soviet Union Air Transport Agreement (SI74/1269) and the UK/Soviet Union Double Taxation Convention (SI86/224). Following independence, the provisions of the UK/Soviet Union agreements continued to be applied by the UK on the basis that they remained in force between the UK and Ukraine until such time as the new agreement (see DT19650 above) became effective.

See DT17450 for details of the UK/Soviet Union agreement. It is not clear whether Ukraine regarded itself as bound by the UK/Soviet Union agreement in this interim period.

Claims for relief in respect of Ukrainian tax in the period between August 1991 and when the UK/Ukraine agreement took effect should be referred to HMRC, Business International, Tax Treaty Team.