Convention between Sweden and Ukraine for the avoidance of double taxation dated 15 August 1995 entered into force on 4 June 1996 (ratified by the Law of Ukraine # 135 dated 23 April 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 20% of the capital of the company paying the dividends;
(b) 10% of the gross amount of the dividends in all other cases.
Paragraph 3. Notwithstanding the provisions of paragraph (2) such dividends shall be taxable only in the Contracting State of which the beneficial owner is a resident if the beneficial owner is a company (other than a partnership) which holds directly at least 25 % of the voting power of the company paying the dividends and at least 50 % of the voting power of the company, which is the beneficial owner of the dividends, is held by residents of that Contracting State.
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. (a) Notwithstanding the provisions of paragraph (2) of this Article, interest arising in a Contracting State where the beneficial owner of such interest is, or the loan for which the interest is paid is guaranteed or insured by, the Government of the other Contracting State or its political subdivisions or local authorities or any agencies thereof, shall be exempt from tax in the first-mentioned Contracting State.
(b) Notwithstanding the provisions of Article 7 of this convention and paragraph (2) of this Article interest arising in a Contracting State where the beneficial owner of such interest is a resident of the other Contracting State shall be exempt from tax in the first-mentioned State, provided that the interest is paid in respect of a loan made, guaranteed or insured on behalf of the other Contracting State by an authority thereof so entrusted.
Paragraph 4. Notwithstanding the provisions of paragraph (2) interest arising in a Contracting State shall be taxable only in the other Contracting State if the recipient is an enterprise of that other State which is the beneficial owner of the interest, and the interest is paid with respect to indebtedness arising on the sale on credit, by that enterprise, of any merchandise or industrial, commercial or scientific equipment to an enterprise of the first-mentioned State, except where the sale or indebtedness is between related persons.
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. Notwithstanding the preceding sentence, if the royalties are paid with respect to any patent concerning industrial and manufacturing know-how or process as well as agriculture, pharmaceutical, computers, software and building constructions, secret formula or process, or for information concerning industrial, commercial or scientific experience, such royalties shall be exempt from tax in the Contracting State in which they arise.
