Ukraine treaty Anti-abuse provisions

Country Ukraine
Treaty article
Date signed 24 October 1995
Date entry into force 02 November 1996


Ukraine

Anti-abuse provision: Main purpose test

Article 11-9:

The provisions of this Article shall not apply if the debt-claim in respect of which the interest is paid was created or assigned mainly for the purpose of taking advantage of this Article. In case a Contracting State intends to apply this paragraph, its competent authority shall in advance consult with the competent authority of the other Contracting State.

Article 12-9:

The provisions of this Article shall not apply if the right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article. In case a Contracting State intends to apply this paragraph, its competent authority shall in advance consult with the competent authority of the other Contracting State.

 Disclaimer

The above is wording of the bilateral treaty between the Netherlands and corresponding country. Please note that the actual wording may deviate from the above wording, this may be due to for example recent amendmends or (pending) treaty negations that have not yet been included in the above wording. Before you use this information, we advise you to contact us to verify the treaty and the specifics of you case. You can reach us via email or office phone number 010-2010466.