The Verkhovna Rada, at a meeting on June 15, 2021, ratified the Protocol between Ukraine and the Kingdom of the Netherlands on amendments to the Convention between the two countries for the avoidance of double taxation and prevention of tax evasion with respect to taxes on income and property.

The Protocol provides for:

  • taxation of dividends at the rate of 5% — if the actual owner of dividends is a company (other than a partnership) that directly owns at least 20% of the capital of the company paying dividends (the provision on taxation of dividends at the rate of 0% is excluded), and 15% — in all other cases;
  • increase in the interest tax rate — from 2% to 5%;
  • increase in the royalty tax rate that is paid for the use or right to use of any copyright in scientific works and patent, trademark, design or model, secret formula, or process, or for information related to industrial, commercial or scientific experience — from 0% to 5%;
  • a new version of the article on information exchange, which provides for a significant expansion of the capabilities of the competent authorities to exchange tax information;
  • rules on the application of the right to receive benefits. Benefits will not be granted in relation to the type of income or property if one of the main purposes of any agreement or agreement between business entities was to directly or indirectly obtain such an advantage.