Convention between Japan and the USSR for the avoidance of double taxation dated 18 January 1986 entered into force on 27 November 1986. Ukraine honours the Convention.
Article 7 (Dividends):
Paragraph 2. Dividends may be taxed in the Contracting State of which the legal person paying the dividends is a resident, and according to the laws of that Contracting State, but if the recipient is the beneficial owner of the dividends the tax so charged shall not exceed 15 % of the gross amount of the dividends.
Article 8 (Interest):
Paragraph 2. Interest may be taxed in the Contracting State in which it arises, and according to the laws of that Contracting 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, interest arising in a Contracting State and derived by the Government of the other Contracting State, local authorities thereof, the Central Bank of that other Contracting State or any financial institution wholly owned by that Government, or by any resident of the other Contracting State with respect to debt-claims guaranteed, insured or indirectly financed by the Government of that Contracting State, local authorities thereof, the Central Bank of that other Contracting State or any financial institution wholly owned by that Government shall be exempt from tax in the first-mentioned Contracting State.
Article 9 (Royalties):
Paragraph 2. (a) Royalties received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films and films or tapes for radio or television broadcasting shall be exempt from tax in the Contracting State in which they arise if the beneficial owner of the royalties is a resident of the other Contracting State.
(b) Royalties received as a consideration for the use of, or the right to use, any patent, trade mark, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience may also be taxed in the Contracting State in which they arise, and according to the laws of that Contracting State. However, the tax so charged shall not exceed 10 % of the gross amount of the royalties if the beneficial owner of the royalties is a resident of the other Contracting State.
