Agreement between Russian Federation and Ukraine for the avoidance of double taxation dated 8 February 1995 entered into force on 3 August 1999 (ratified by the Law of Ukraine # 369 dated 6 October 1995).
Article 10 (Dividends):
Paragraph 2. Dividends may be taxed in the Contracting State of which the enterprise paying the dividends is a resident and according to the laws of that State, but if the recipient is the beneficial owner of the dividends the tax so charged shall not exceed:
(a) 5% of the gross amount of the dividends if the resident of the other Contracting State contributed to its shareholding capital (charter fund) at least 50,000 US Dollars or the equivalent amount in the national currencies of the Contracting States; or
(b) 15% of the gross amount of the dividends in all other cases.
Article 11 (Interest):
Paragraph 2. Interest may be taxed in the Contracting State in which it arises and according to the laws of that State, but if the recipient is the beneficial owner of the interest, the tax so charged shall not exceed 10 % of the gross amount of the interest.
Paragraph 3. Notwithstanding the provisions of paragraph 2 of this Article, interest arising:
(a) in Russia and paid to the Government of Ukraine or the National Bank of Ukraine, any other authority created therein as well as in respect of credit guaranteed by them shall be exempt from Russian tax;
(b) in Ukraine and paid to the Government of Russia or the Central Bank of Russia, any other state authority created therein as well as in respect of credit guaranteed by them shall be exempt from Ukrainian tax.
Article 12 (Income from copyrights and licenses (royalties)):
Paragraph 2. Royalties may be taxed in the Contracting State in which they arise and according to the laws of that State, but the tax so charged shall not exceed 10 % of the gross amount of the royalties.
