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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
Updated
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Ukraine: Dividends

Ukrainian tax deducted from dividends paid by a Ukrainian company at the agreement rate of 10 per cent (5 per cent if the dividend is paid to a United Kingdom resident company controlling, directly or indirectly, at least 20 per cent of the voting power in the company paying the dividend) qualifies for credit as a direct tax (see INTM164010(c)).

The reductions to the above rates are not given where the dividends are effectively connected with (see INTM153110 fifth sub-paragraph) a permanent establishment or fixed base which the recipient has in Ukraine (Article 10(4)).

Where a dividend is paid to a United Kingdom-resident company controlling, directly or indirectly, at least 10 per cent of the voting power in the company paying the dividend, relief is also due under the agreement for underlying tax (see INTM164010(d) and Article 22(1)(b)).