Analysis of Double Tax Relief Provisions in Double Tax Treaties Between Ukraine and Member States of the European Union

Abstract

The master thesis analyses double taxation preclusion between Ukraine and European Union Member States. Exemption and credit double taxation preclusion methods are described alongside their subtypes (full exemption, exemption with progression, full credit, ordinary credit). The analysis establishes that the full exemption method is the most beneficial for taxpayers since it allows them to pay less tax in the residence state, while the ordinary credit is the most burdensome in this regard. The thesis lists particular EU Member States that apply exemption and credit to their taxpayers operating in Ukraine through a permanent establishment. The thesis reveals that Ukraine uses the ordinary credit method for its taxpayers, possessing a permanent establishment in the EU. Subsequently, an author recommends that the Ukrainian legislator implements the full exemption method for those taxpayers who operate in the EU to incentivize their economic presence in the Union.