Brazil

Convention between Brazil and Ukraine for the avoidance of double taxation dated 16 January 2002 entered into force on 24 April 2006 (ratified by the Law of Ukraine # 60-IV dated 04 July 2002).

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) 10 % of the gross amount of the dividends if the beneficial owner is a company which controls directly at least 25 % of the voting power in 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 a resident of the other Contracting State is the beneficial owner of the interest the tax so charged shall not exceed 15 % of the gross amount of the interest.

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 15 % of the gross amount of all payments.



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