Convention between Estonia and Ukraine for the avoidance of double taxation dated 10 May 1996 entered into force on 24 December 1996 (ratified by the Law of Ukraine # 368 dated 13 September 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 paragraph 2 of this Article, interest arising in a Contracting State, derived and beneficially owned by the Government of the other Contracting State, including political subdivisions and local authorities thereof, the Central Bank or any financial institution wholly owned by that Government, or interest derived on loans guaranteed by that Government shall be exempt from tax in the first-mentioned State.
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 the recipient is the beneficial owner of the royalties, the tax so charged shall not exceed 10% of the gross amount of the royalties.
