Ukraine & Malta Double Tax Treaty

A double tax treaty between Malta and the Ukraine was signed on 4 September 2013 and published on 6 December 2017. It entered into force from 28 August 2017.

Ukraine-Malta Double Tax Treaty

Ukraine Withholding Taxes

The main features of the Malta-Ukraine tax treaty are as follows.

Elimination of double taxation

Tax suffered in the source country is normally eliminated by applying a credit for tax paid against the tax liability for that income in the residence country.

Dividend Income

The double tax treaty between Malta and the Ukraine sets out a maximum withholding tax of 5 per cent on a payment of dividends from a company in the Ukraine to a Malta company holding at least 20% of the capital of the Ukrainian company. In all other circumstances, the maximum withholding tax should be no more than 15 per cent.

Interest Income

The double tax treaty between Malta and the Ukraine sets out a maximum withholding tax of 10 per cent on interest paid to the beneficial owner thereof.

Royalty Income

The double tax treaty between Malta and the Ukraine sets out a maximum withholding tax of 10 per cent on royalties paid to the beneficial owner thereof.

Artistes and Sportsmen

Income derived by a person from entertainment or sports may be taxed in the state where the activities are exercised.

Pensions

Pensions and similar remuneration in consideration of past employment (other than pensions paid by or out of funds created by a state or political subdivisions/local authority in respect of services rendered to that state or political subdivision/local authority) shall be taxable in the country of residence only.

Other income

Income not specifically dealt with in the Malta Ukraine double tax treaty shall be taxable in the country of residence only.

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When navigating tax matters from Malta to Ukraine and from Ukraine to Malta, it’s essential to understand how the Double Tax Treaty between the two countries impacts taxation on income, capital gains, and other financial obligations. This treaty ensures that individuals and businesses benefit from reduced tax liabilities and avoid the risk of double taxation. By leveraging this agreement, both residents and companies can optimise their tax position when operating or investing across Malta to Ukraine or Ukraine to Malta. Please contact us should you require any more information on the Malta-Ukraine Double Tax Treaty and the unique tax planning opportunities.

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