Convention between Thailand and Ukraine for the avoidance of double taxation dated 10 March 2004 entered into force on 24 November 2004 (ratified by the Law of Ukraine # 2035 dated 22 September 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) 10 % of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent of the capital of 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 the beneficial owner of the interest is a resident of the other Contracting State, the tax so charged shall not exceed:
(a) 10 % of the gross amount of the interest, in the case of interest arising in a Contracting State and paid on any loans granted by a bank or any other financial institution of the other Contracting State, including investment banks and savings banks, and insurance companies; or
(b) 15 % of the gross amount of the interest in all other cases.
Paragraph 3. Notwithstanding the provisions of paragraph 2, interest arising in a Contracting State and derived by the Government of the other Contracting State, a political subdivision or a local authority thereof, the Central Bank of that other Contracting State or any other financial institution established and owned by the Government of the other Contracting State to promote trade and investment, or by any resident of the other Contracting State with respect to debt-claims guaranteed, insured by the Government of that other Contracting State, a local authority thereof, the Central Bank of the other Contracting State or any other financial institution established and owned by the Government of the other Contracting State to promote trade and investment shall be exempt from tax in the first-mentioned Contracting State.
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 beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 15 % of the gross amount of the royalties.
