Convention between Canada and Ukraine for the avoidance of double taxation dated 4 March 1996 entered into force on 22 August 1996 (ratified by the Law of Ukraine # 339 dated 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 a resident of the other Contracting State 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 controls directly or indirectly, in the case of Canada at least 20 % of the voting power in the company paying the dividends and in the case of Ukraine at least 20 % of the authorised capital in the company paying the dividends;
(b) 15 % of the gross amount of the dividends in the case of dividends paid by a non-resident owned investment corporation that is a resident of Canada and 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 a resident of the other Contracting State 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:
(a) interest arising in a Contracting State and paid in respect of indebtedness of the government of that State or of a political subdivision or local authority thereof shall, provided that the interest is beneficially owned by a resident of the other Contracting State, be taxable only in that other State;
(b) interest arising in a Contracting State and paid to a resident of the other Contracting State shall be taxable only in that other State if it is paid in respect of a loan made, guaranteed or insured, or a credit extended, guaranteed or insured by an entity wholly-owned and controlled by the government of that other State, provided the loan or credit is in respect of imports or exports;
(c) interest arising in a Contracting State and paid to a resident of the other Contracting State which was constituted and is operated exclusively to administer or provide benefits under one or more pension, retirement or other employee benefits plans shall not be taxable in the first-mentioned State provided that:
(i) the resident is the beneficial owner of the interest and is generally exempt from tax in the other State; and
(ii) the interest is not derived from carrying on a trade or a business or from a related person.
Article 12 (Royalties):
Paragraph 2. Royalties may be taxed in the Contracting State in which they arise and according to the laws of that State, but if a resident of the other Contracting State is the beneficial owner of the royalties the tax so charged shall not exceed 10 % of the gross amount of the royalties.
Paragraph 3. Notwithstanding the provisions of paragraph 2, royalties arising in a Contracting State and paid to a resident of the other Contracting State who is the beneficial owner of the royalties, shall be taxable only in that other State if they are royalties for the use of, or the right to use, computer software.
