Convention between Belgium and Ukraine for the avoidance of double taxation dated 20 May 1996 entered into force on 25 February 1999 (ratified by the Law of Ukraine # 433 dated 29 October 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 which holds directly at least 20 % 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:
(a) 2 % of the gross amount of the interest which is paid:
(i) in connection with the sale on credit of any industrial, commercial or scientific equipment or in connection with the sale or supply on credit of any merchandise or services by an enterprise to another enterprise;
(ii) on loans of any nature -- not represented by bearer instruments - granted by a bank or any other financial institution;
(b) 5 % of the gross amount of the interest in all other cases.
Paragraph 3. Notwithstanding the provisions of paragraph 2 of this Article, interest arising in a Contracting State shall be exempt from tax in that State if it is:
(a) interest received and beneficially owned by the other Contracting State itself, one of its political subdivisions, or any agency owned or controlled by that Contracting State or that subdivision;
(b) interest beneficially owned by a resident of the other Contracting State and paid to him in respect of a loan or any other debt-claim or credit granted, guaranteed or insured by public entities owned or controlled by that other Contracting State the objective of which is to promote the export and which are specified and agreed in letters exchanged between the competent authorities of the Contracting States.
Article 12 (Royalties):
Paragraph 2. Royalties may be taxed in the Contracting State in which they arise and in accordance with the laws of that State, but if the recipient is the beneficial owner of the royalties the tax so charged shall not exceed 5% of the gross amount of the royalties within the meaning of subparagraph (a) of paragraph 4 of this Article.
Paragraph 3. Notwithstanding the provisions of paragraph 2 of this Article, royalties arising in a Contracting State and paid to a resident of the other Contracting State shall be taxed only in the other Contracting State if such resident is the beneficial owner of the royalties and if the royalties are payments within the meaning of subparagraph (b) of paragraph 4 of this Article.
Paragraph 4. The term "royalties" as used in this Article means payments of any kind received as a consideration:
(a) for the use of, or the right to use, any copyright of literary or artistic work including cinematograph films, and films or tapes for radio or television broadcasting; and
(b) for the use of, or the right to use, any copyright of scientific work, any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience.
