Agreement between Vietnam and Ukraine for the avoidance of double taxation dated 8 April 1996 entered into force on 19 November 1998 (ratified by the Law of Ukraine # 431 dated 29 October 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 10% of the gross amount of the dividends.
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:
(a) interest arising in Ukraine shall be taxable only in Vietnam if the interest is paid to:
(i) the Government of Vietnam, a political-administrative subdivision, a local authority or its statutory body;
(ii) the Central Bank of Vietnam;
(iii) divisions that wholly belong to the Government of Vietnam or any local authority which from time to time can be agreed upon between the competent authorities of the Contracting States;
(b) interest arising in Vietnam shall be taxable only in Ukraine it the interest is paid to:
(i) the Government of Ukraine, a political subdivision, a local authority or its statutory body;
(ii) the National Bank of Ukraine;
(iii) divisions that wholly belong to the Government of Ukraine or any local authority which from time to time can be agreed upon between the competent authorities of the Contracting States.
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.
