The pending protocol to the 1996 income and capital tax treaty between Turkey and Ukraine was signed on 9 October 2017. The protocol is the first to amend the treaty and includes the following changes:

• Article 2 (Taxes Covered) is updated in respect of the taxes covered for both countries;
• Article 3 (General Definitions) is amended to expand (clarify) the provision regarding terms not defined under the treaty;
• Article 4 (Resident) is updated to include a State and any political subdivision or local authority within the definition of “resident of a Contracting State”;
• Article 8 (International Transport) is amended to include road vehicles in relation to profits from the use, maintenance, or rental of containers in international traffic;
• The wording of Articles 10 (Dividends), 11 (Interest), and 12 (Royalties) is amended for clarity, including that a beneficial owner of a Contracting State is eligible for the treaty withholding rates and not just a beneficial owner (the rates are not changed);
• Article 15 (Dependent Personal Services) is amended to correct a typo in the reference to work carried out in connection with a building site, construction, assembly or installation project (original referred to the wrong subparagraph of Article 5);
• Article 26 (Exchange of Information) is replaced to bring it in line with the OECD standards for information exchange; and
• A new Article 26A (Assistance in the Collection of Taxes) is inserted.

The protocol will enter into force on the last day of the month following the month the ratification instruments are exchanged and will apply from 1 January of the year following its entry into force.