Convention between Georgia and Ukraine for the avoidance of double taxation dated 14 February 1997 entered into force on 1 April 1999 (ratified by the Law of Ukraine # 922 dated 13 July 1999).
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 at least 25 % of the capital of the company paying the dividends;
(b) 10 % 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 8. 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 received and really held by the Government of the other Contracting State or its local authority, or any agency, or with the help of this Government or local authority.
Paragraph 9. Notwithstanding the provisions of Article 7 of this Convention and paragraph 2 of this Article, interest arising in a Contracting State paid to and directly held by a resident of the other Contracting State shall be exempt from tax in the first-mentioned State if it was paid in respect of loan made, guaranteed or insured, or in respect of any other debt-claim or credit guaranteed or insured on behalf of the other Contracting State by its authorised organ.
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 the tax so charged shall not exceed 10% of the gross amount of the royalties.
