🇺🇦 Tax Treaty
Cyprus–Ukraine Double Tax Treaty
The Cyprus-Ukraine DTA historically provided some of the lowest withholding rates for interest (2%) and royalties (5%) in Cyprus's treaty network. Verify current status given ongoing conflict.
Withholding Tax Rates at a Glance
(reduced rate)
(Cyprus side)
Full Withholding Tax Rates
| Payment Type | Treaty Rate | Conditions |
|---|---|---|
| Dividends (standard) | 15% | Standard WHT rate |
| Dividends (reduced) | 5% | companies holding ≥20% of payer capital and investing ≥EUR 100,000 |
| Interest | 2% | On interest payments between the countries |
| Royalties | 5% | On royalties, licences, and IP income |
| Capital Gains (Cyprus side) | 0% | 0% in Cyprus on disposal of shares |
Treaty signed: 2012. In force: 2013. Rates are treaty maxima — domestic law or EU directives may reduce them further.
Key Treaty Benefits
- ✓ 2% WHT on interest (exceptionally low)
- ✓ 5% WHT on royalties
- ✓ 5% WHT on dividends for qualifying holdings
Common Cyprus–Ukraine Structures
- → Cyprus holding company above Ukrainian operating entity
- → Cyprus IP company licensing to Ukrainian software companies
Planning Notes
Ukraine has suspended some aspects of treaty operations due to the ongoing conflict. Verify current applicability for any Ukraine-sourced payments. Historically this was an important treaty for CIS-area entrepreneurs.
Dual Residency Tiebreaker
Mutual agreement procedure
Planning a Cyprus–Ukraine structure?
Treaty rates are only part of the picture. We help you design and implement Cyprus company structures that take full advantage of the Cyprus–Ukraine double tax treaty — with genuine substance and robust documentation.