Convention between Denmark and Ukraine for the avoidance of double taxation dated 5 March 1996 entered into force on 21 August 1996 (ratified by the Law of Ukraine # 341dated 12 July 1996).
Article 10 (Dividends):
Paragraph 2. Dividends may be taxed in the Contracting State of which the company 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 beneficial owner is a company (other than a partnership) which holds directly at least 25 % of the capital of the company paying the dividends;
(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 paragraphs 1 and 2,
(a) interest arising in Ukraine shall be exempt from Ukrainian tax if the interest is paid to:
(i) the State of Denmark, a political subdivision, a local authority or a statutory body thereof;
(ii) the National Bank of Denmark;
(iii) the Industrialisation Fund for Developing Countries;
(iv) the Investment Fund for Central and Eastern Europe;
(b) interest arising in Denmark shall be exempt from Danish tax if the interest is paid to:
(i) the State of Ukraine, a political subdivision, a local authority or a statutory body thereof ;
(ii) the National Bank of Ukraine;
(c) any other institution which is a resident of a Contracting State shall be exempt from the tax in the other Contracting State with respect to interest paid to such institution and arising in that other State if such institution is defined by mutual agreement between the competent authorities of the two States as being similar to those institutions mentioned in subdivision (a) (iii)-(iv);
(d) interest arising in a Contracting State on a loan guaranteed by any of the bodies mentioned or referred to in sub-paragraph (a) or (b) and paid to a resident of the other Contracting State shall be taxable only in that State;
(e) interest arising in a Contracting State shall be taxable only in the other Contracting State if:
(i) the recipient is a resident of that other State, and
(ii) such recipient is an enterprise of that other State and the beneficial owner of the interest, and
(iii)the interest is paid in respect of indebtedness incurred in connection with the sale on credit by that enterprise, of any industrial, commercial or scientific equipment, to an enterprise of the first-mentioned State, except where the sale or indebtedness is between associated enterprises within the meaning of Article 9.
Article 12 (Royalties):
Paragraph 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State.
Paragraph 2. Royalties, except those referred to in sub-paragraph (b) of paragraph 3, may also be taxed in the Contracting State in which they arise and in accordance with the laws of that State, but if the beneficial owner of the royalties is a resident of the other Contracting State the tax so charged shall not exceed 10 % of the gross amount of the royalties.
Paragraph 3. The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use:
(a) any copyright of literary, artistic or scientific work (including cinematograph films, and films or tapes for radio or television broadcasting), trade mark, patent, design, model or plan;
(b) any secret formula or process, or for information (know-how) concerning industrial, commercial or scientific experience.
