Switzerland and Ukraine government officials today signed a protocol amending their 2000 tax treaty.
The protocol, which is not yet in force, would reduce the threshold ownership interest in a distributing company for a dividend to be considered qualified participation.
Under the protocol, that threshold is set at 10 percent; the current standard of 20 percent.
The protocol also adds minimum standards agreed to by nations in the OECD/G20 base erosion profit shifting (BEPS) on tax treaty shopping. It also provides for arbitration of tax disputes.
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