Convention between South Africa and Ukraine for the avoidance of double taxation dated 28 August 2003 entered into force on 23 December 2004 (ratified by the Law of Ukraine # 1437 dated 4 February 2004).
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 beneficial owner of the dividends is a resident of the other Contracting State, 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 20% of the capital of the company paying the dividends; or
(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 beneficial owner of the interest is a resident of the other Contracting State, the tax so charged shall not exceed 10% of the gross amount of the interest.
Paragraph 3. Notwithstanding the provisions of paragraph 2, interest arising in a Contracting State shall be exempt from tax in that State if:
(a) the payer of the interest is the Government of that Contracting State, a political subdivision or local authority thereof, or
(b) the interest is paid to the Government of the other Contracting State, a political subdivision, a local authority or the Central Bank thereof or any agency or instrumentality (including a financial institution) wholly owned by that other Contracting State, a political subdivision or local authority thereof; or
(c) the interest is paid in relation to loans made in application of an agreement concluded between the Governments of the Contracting States.
Article 12 (Royalties):
Paragraph 2. Royalties 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 royalties the tax so charged shall not exceed 10% of the gross amount of the royalties.
