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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Ukraine: Partnerships

Under Article 3(2), a partnership or joint venture which derives its status from Ukrainian law, and is therefore treated as a taxable unit in Ukraine, is regarded as a `person’ for the purposes of the agreement. As such it may be entitled to claim treaty benefits, such as exemption from United Kingdom tax, in respect of certain sources of income. This has no effect, however, on the United Kingdom’s right to tax United Kingdom-resident partners in Ukrainian partnerships which benefit from the agreement. Credit for Ukrainian tax paid by the partnership will be available, subject to the other provisions of the agreement, to United Kingdom-resident partners (Article 24).

A United Kingdom resident who is a member of a partnership which is not a resident of Ukraine may claim relief or exemption from Ukranian tax in respect of his share of the income of the partnership as if he had derived that income directly.