Welcome to Scribd, the world's digital library. Read, publish, and share books and documents. See more
Standard view
Full view
of .
Look up keyword
Like this
1Activity
0 of .
Results for:
No results containing your search query
P. 1
Cyprus Ukraine Dtt 2012

Cyprus Ukraine Dtt 2012

Ratings: (0)|Views: 22|Likes:

More info:

Published by: Alexander S. Zakharov on Nov 21, 2012
Copyright:Attribution Non-commercial

Availability:

Read on Scribd mobile: iPhone, iPad and Android.
See more
See less

12/04/2012

 
Provided by DS Express, Inc.
 
 
CONVENTION BETWEEN THE GOVERNMENT OF THE REPUBLICOF CYPRUS AND THE GOVERNMENT OF UKRAINE FOR THEAVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OFFISCAL EVASION WITH RESPECT TO TAXES ON INCOME OF 2012КОНВЕНЦИЯ МЕЖДУ ПРАВИТЕЛЬСТВОМ РЕСПУБЛИКИ КИПРИ ПРАВИТЕЛЬСТВОМ УКРАИНЫ ОБ ИЗБЕЖАНИИ ДВОЙНОГОНАЛОГООБЛОЖЕНИЯ И ПРЕДОТВРАЩЕНИИ УКЛОНЕНИЯ ОТНАЛОГООБЛОЖЕНИЯ В ОТНОШЕНИИ НАЛОГОВ НА ДОХОДЫ2012 ГОДА
Article 1PERSONAL SCOPE
This Convention shall apply to persons who are residents of one or both of the ContractingStates.
Article 2TAXES COVERED
1.This Convention shall apply to taxes on income imposed on behalf of a ContractingState or of its political subdivisions or local authorities, irrespective of the manner in whichthey are levied. 2.There shall be regarded as taxes on income all taxes imposed on total income, or onelements of income including taxes on gains from the alienation of movable or immovable property and taxes on the total amounts of wages or salaries paid by enterprises. 3.The taxes which are the subject of this Convention are:(a)in the case of Cyprus:(i)the income tax;(ii)the corporate income tax;(iii)special contribution for the Defence of the Republic; and(iv)the capital gains tax;(hereinafter referred to as "Cyprus tax");(b)in the case of Ukraine:(i)the tax on profits of enterprises; and(ii)the individual income tax.(hereinafter referred to as "Ukrainian tax"). 4.This Convention shall apply also to any identical or substantially similar taxes whichare imposed by either Contracting State after the date of signature of this Convention inaddition to, or in place of, the existing taxes. The competent authorities of the ContractingStates shall notify each other of any substantial changes which have been made in their respective taxation laws.
Article 3GENERAL DEFINITIONS
 
2
1.For the purposes of this Convention, unless the context otherwise requires:(a)the term "Cyprus" means the Republic of Cyprus and, when used in a geographicalsense, includes the national territory, the territorial sea thereof as well as any areaoutside the territorial sea, including the contiguous zone, the exclusive economiczone and the continental shelf, which has been or may hereafter be designated, under the laws of Cyprus and in accordance with international law, as an area within whichCyprus may exercise sovereign rights or jurisdiction;(b)the term "Ukraine" when used in geographical sense, means the territory of Ukraine,its continental shelf and its exclusive (maritime) economic zone, including any areaoutside the territorial sea of Ukraine which in accordance with international law has been or may hereafter be designated, as an area within which the rights of Ukrainewith respect to the seabed and subsoil and their natural resources may be exercised;(c)the term "national" means:(i)any individual possessing the nationality or citizenship of a ContractingState;(ii)
any legal person, partnership or association deriving its status from thelaws in force in a Contracting State;
(d)the terms "a Contracting State" and "the other Contracting State" mean Ukraine oCyprus as the context requires;(e)the term "person" includes an individual, a company and any other body of persons;(f)the term "company" means any body corporate or any entity which is treated as a body corporate for tax purposes;(g)the terms "enterprise of a Contracting State" and "enterprise of the other ContractingState" mean respectively an enterprise carried on by a resident of a Contracting Stateand an enterprise carried on by a resident of the other Contracting State;(h)the term "international traffic" means any transport by a ship, boat or aircraft,operated by an enterprise of a Contracting State, except when the ship, boat or aircraft, is operated solely between places in the other Contracting State;(i)the term "competent authority" means, in the case of Cyprus, the Minister of Financeor his authorized representative, and, in the case of Ukraine, the Ministry of Financeof Ukraine or its authorized representative;(j)the term "enterprise" applies to the carrying on of any business;(k)the term "business" includes the performance of professional services and of other activities of an independent character. 2.As regards the application of the Convention by a Contracting State any term notdefined therein shall, unless the context otherwise requires, have the meaning which it hasunder the law of that State concerning the taxes to which the Convention applies.
Article 4RESIDENT
1.For the purposes of this Convention, the term "resident of a Contracting State" meansany person who, under the laws of that State, is liable to tax therein by reason of his domicile,residence, place of management, place of registration or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof.But this term does not include any person who is liable to tax in that State in respect only of income from sources in that State. 
Текст Конвенции между Правительством Республики Кипр и Правительством Украины об избежании двойногоналогообложения и предотвращении уклонения от налогообложения в отношении налогов на доходы 2012 года
 Предоставлен
DS Express, Inc. 
http :// www .dsexpress .com© С 1992 года с офшорами на «ты».
 
3
2.Where by reason of the provisions of paragraph 1 of this Article an individual is aresident of both Contracting States, then his status shall be determined as follows:(a)he shall be deemed to be a resident of the Contracting State in which he has a permanent home available to him; if he has a permanent home available to him in both Contracting States, he shall be deemed to be a resident of the Contracting Statewith which his personal and economic relations are closer (centre of vital interests);(b)if the Contracting State in which he has his centre of vital interests cannot bedetermined, or if he has no permanent home available to him in either ContractingState, he shall be deemed to be a resident of the Contracting State in which he has anhabitual abode;(c)if he has an habitual abode in both Contracting States or in neither of them, he shall be deemed to be a resident of the Contracting State of which he is a national;(d)if he is a national of both Contracting States or of neither of them, the competentauthorities of the Contracting States shall settle the question by mutual agreement. 3.Where by reason of the provisions of paragraph 1 of this Article a person other thanan individual is a resident of both Contracting States, then it shall be deemed to be a residentof the Contracting State in which its place of effective management is situated.
Article 5PERMANENT ESTABLISHMENT
1.For the purposes of this Convention, the term "permanent establishment" means afixed place of business through which the business of an enterprise is wholly or partly carriedon. 2.The term "permanent establishment" includes especially:(a)a place of management;(b)a branch;(c)an office;(d)a factory;(e)a workshop;(f)an installation or structure for the exploration of natural resources;(g)a mine, an oil or gas well, a quarry or any other place of extraction of naturalresources; and(h)a warehouse or other structure used for sale of goods. 3.A building site or construction or installation project or any supervisory activities inconnection with such site or project constitutes a permanent establishment only if it lasts morethan twelve months. 4.Notwithstanding the preceding provisions of this Article, the term "permanentestablishment" shall be deemed not to include:(a)the use of facilities solely for the purpose of storage, display or delivery of goods omerchandise belonging to the enterprise;(b)the maintenance of a stock of goods or merchandise belonging to the enterprisesolely for the purpose of storage, display or delivery;(c)the maintenance of a stock of goods or merchandise belonging to the enterprisesolely for the purpose of processing by another enterprise;(d)the maintenance of a fixed place of business solely for the purpose of purchasing
Текст Конвенции между Правительством Республики Кипр и Правительством Украины об избежании двойногоналогообложения и предотвращении уклонения от налогообложения в отношении налогов на доходы 2012 года
 Предоставлен
DS Express, Inc. 
http :// www .dsexpress .com© С 1992 года с офшорами на «ты».

You're Reading a Free Preview

Download
scribd
/*********** DO NOT ALTER ANYTHING BELOW THIS LINE ! ************/ var s_code=s.t();if(s_code)document.write(s_code)//-->