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.

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Ukraine-Singapore DTAA: Double Tax Avoidance Agreement
ukraine-singapore tax treaty analysis

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

The Singapore-Ukraine DTAA applies to all residents (individuals and legal entities) of one or both countries. Therefore, if you are a resident of Singapore, Ukraine, or both, then you can avail the provisions of this DTAA.

What Taxes Will I Owe Under the Ukraine-Singapore Double Tax Agreement?

The tax you owe will depend on the country where you have to pay the tax which further depends on the type of income involved, and the maximum rate specified (if any) in the DTAA for that type of income. The key provisions of the Ukraine-Singapore DTAA are described in the following sections.

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Ukraine-Singapore Double Tax Avoidance Agreement at a Glance

The DTAA specifically states where the different types of income of a resident of either Singapore or Ukraine will be subject to tax. The following table states the type of income or payments made and the state where the income is taxed. This is important since the place of taxation will determine the rate of tax applicable to that type of income under the DTAA.

Type of income or payment

Where it is taxed

Income from immovable property

Taxed in the state where the property is situated

Business profits

 Taxed in the country where the company is managed and controlled.

Permanent Establishment income

Taxed in the country where the PE is situated and carries out its business, but only on the amount attributable to that PE.

Profits from shipping and air transport

Profits derived from the operation of ships and aircraft in international traffic by an enterprise that is resident of a country, shall be taxable only in that country.


Taxed in the country where the recipient resides.


Taxed in the country where the recipient resides.


Taxed in the country where the recipient resides.

Capital gains

Taxed in the country where the property is located.

Technical fees

Taxed in the country from which the fees are derived. The tax shall not exceed 5% of the gross amount of the technical fees.

Independent personal service

Taxed in the country where the recipient resides unless he has a fixed base regularly available in the other country for the purpose of performing his or her activities, or his or her stay in the other country is for more than 183 days in any twelve-month period.

Dependent personal services (salaries, wages, and other similar remuneration)

Taxed in the country where the recipient resides unless the employment is exercised in the other country. However, there are some exceptions.

Directors’ fees

Taxed in the country where the company (paying the directors’ fees) resides.

Artists & sportsmen

Taxed in the country where activities are performed.

Pensions and other similar remuneration (including any annuity)

Taxed in the country where the recipient resides.

Government service

Taxed by the government of that country unless the individual is a resident of the other country where he or she performs the services.

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.
Income (wherever arising) that cannot be included in the above-mentioned categories shall be taxable only in the country where the recipient resides.

Protocol Amending the DTA 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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