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HMRC internal manual

Double Taxation Relief Manual

Ukraine: Interest and royalties

Interest or royalties arising in Ukraine and paid to a resident of the United Kingdom who is both the beneficial owner of the interest or royalties and subject to tax in respect of the interest or royalties, are exempt from Ukrainian tax (Articles 11(1) and 12(1)), except where the interest or royalty is effectively connected with (see INTM153110) a permanent establishment or fixed base which the United Kingdom resident recipient has in Ukraine. In the latter circumstances, the provisions of the Business Profits Article (Article 7) or the Independent Personal Services Article (Article 14) will apply.