Details of the amending Protocol to the 2012 Income Tax Treaty between Cyprus and Ukraine have become available.
In accordance to the amending Protocol, the withholding taxes on dividends is amended as follows:
the minimum rate on dividends has been raised to 5% and is applicable where the recipient holds 20% percent or more of the shares in the company distributing the dividend and invested at least EUR100.000 for that holding;
otherwise a 10% rate applies.
The two countries shall notify each other in writing, on the completion of the procedures required by the domestic law for bringing into force of the Protocol.
The protocol shall enter into force on the date that the latter of the notifications referred to above and shall have effect:
in respect of taxes withheld at source, on amounts paid or credited to non-residents either on or after the 1st of January 2019 or the first day of January of the calendar year next following that in which this Protocol enters into force if this date is later than the 1st of January 2019; and
in respect of other taxes for taxable years or periods beginning on the 1st of January 2019 or after the first day of January of the year next following the entry into force of this Protocol if this date is latter than the 1st of January 2019.
Source: World.tax 10.08.2016