Convention between Portugal and Ukraine for the avoidance of double taxation dated 9 February 2000 entered into force on 11 March 2002 (ratified by the Law of Ukraine # 2326 dated 22 March 2001).
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 15 % of the gross amount of the dividends.
Paragraph 3. Notwithstanding the provisions of paragraph 2, if the beneficial owner is a company that, for an uninterrupted period of two years prior to the payment of the dividend, owns directly at least 25 % of the capital stock (capital social) of the company paying the dividends, the tax so charged shall not exceed 10 % of the gross amount of such 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 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 or a local authority thereof; or
(b) the interest is paid to the Government of the other Contracting State or local authority thereof or any institution (including a financial institution) wholly owned by that other Contracting State or local authority thereof; or
(c) the interest is paid to any other institution (including a financial institution) in relation to loans made under 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 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.
