Ukraine-Singapore DTAA: Double Tax Avoidance Agreement
Bilateral economic ties between Singapore and Ukraine have strengthened in recent years. The two countries are exploring opportunities for sharing knowledge, cross-learning, and deeper integration in areas of economic development, business regulations, science, and technology. With these objectives in mind, the Singapore-Ukraine Double Tax Treaty has been designed to facilitate trade and investment between the two countries.
This article will highlight the important provisions of the Singapore-Ukraine DTAA, its tax applicability, tax rates, scope, and other advantages of this DTAA.
What Is the DTAA between Ukraine and Singapore?
A double tax treaty is an important policy tool to prevent double taxation. It provides relief from double taxation and prevents (or minimizes) other forms of tax discrimination and tax obstacles to cross-border trade and investment between the two countries.
Singapore and Ukraine signed a Double Tax Avoidance Treaty (DTAA) on 26 January 2007 and the agreement came into force in 2010. In addition, the two countries have signed the Multilateral Instrument to Prevent Base Erosion and Profit Shifting which affects withholding tax covered by the double tax treaty on payments made after 1 January 2020.
Furthermore, on 4 March 2020, the DTAA Protocol was implemented to amend the treaty and bring it in line with OECD standards for information exchange. These amendments are designed to help the two countries accurately monitor income flows between them and enforce their tax rules.
Scope of Ukraine-Singapore DTAA
What Taxes Will I Owe Under the Ukraine-Singapore Double Tax Agreement?
Double Tax Avoidance Agreement at a Glance
Type of income or payment
Where it is taxed
Income from immovable property
Permanent Establishment income
Profits from shipping and air transport
Independent personal service
Dependent personal services (salaries, wages, and other similar remuneration)
Artists & sportsmen
Pensions and other similar remuneration (including any annuity)
Payments to students and trainees
Payments that a student or trainee receives for the purpose of his or her maintenance, education or training are not taxed in the country of education (Country A) if:
- A student or trainee is a resident of the other country (Country B)
- A student or trainee is present in Country A solely for the purpose of his or her education or training
- Such payments arise from sources outside of the Country A.
Protocol Amending the Agreement Between Singapore and Ukraine
In recent years, tax authorities of the two countries have become more active in their collaboration with their counterparts in order to gather information on cross-border transactions and the counterparties of such transactions in order to ensure that the transactions represent genuine economic activity and are not designed merely to evade taxes. For this purpose, in 2019 the Governments of Ukraine and Singapore signed the Protocol amending the Double Tax Treaty between the two countries.
The Protocol amends the Exchange of Information Article in order to align it with existing internationally-agreed standard on exchange of information on request. In particular, the document adds provisions that prohibit the tax authorities from rejecting an information request from their foreign colleagues without a sound reason for such rejection. This change strengthens tax cooperation between the two countries.
On 4 March 2020, this amendment to the Ukraine-Singapore agreement on avoidance of double taxation was entered into force.
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