Convention between Switzerland and Ukraine for the avoidance of double taxation dated 30 October 2000 entered into force on 26 February 2002 (ratified by the Law of Ukraine # 2929 dated 10 January 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 the recipient is the beneficial owner of the dividends the tax so charged shall not exceed:
(a) 5 % of the gross amount of the dividends if the beneficial owner of the dividends is a company (other than a partnership) which holds directly at least 20% 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 10 % of the gross amount of the interest.
Paragraph 3. Notwithstanding the provisions of paragraph 2 any interest mentioned in paragraph 1 shall be taxed only in the Contracting State of which the recipient is the resident, if such recipient is the beneficial owner of the interest and if such interest is paid:
(a) with respect to sale on credit of any industrial, commercial or scientific equipment;
(b) with respect to sale on credit of any products by one enterprise to another enterprise;
(c) on any loans provided by bank; or
(d) to the Contracting State or its political-administrative subdivision or local authority.
Article 12 (Royalties):
Paragraph 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State.
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 in the meaning of paragraph 5 subparagraph (a) of this Article.
Paragraph 3. Notwithstanding the provisions of paragraph 2 of this Article, royalties arising in a Contracting State and paid to a resident of the other Contracting State shall be taxed only in the other Contracting State if that resident is the beneficial owner or the royalties and if the royalties are payments in the meaning of paragraph 5 subparagraph (b) of this Article.
Paragraph 5. The term "royalties" as used in this Article means payments of any kind received as a consideration:
(a) for the use of, or the right to use, any copyright of literary or artistic work (including cinematography films, and films or tapes for radio or television broadcasting); and
(b) for the use of, or the right to use, any copyright of scientific work, patent, trade mark, design or model, plan, secret formula or process, or for information (know-how) concerning industrial, commercial or scientific experience.
