Agreement between Kyrgyzstan and Ukraine for the avoidance of double taxation dated 16 October 1997 entered into force on 1 May 1999 (ratified by the Law of Ukraine # 505 dated 17 March 1999).
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 the resident of the other Contracting State the tax so charged shall not exceed:
(a) 5% of the gross amount of the dividends if the beneficial owner is a company, and this company holds at least 50% 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 recipient is the beneficial owner of the interest, the tax so charged shall not exceed 10% of the gross amount of the interest.
Paragraph 7. Notwithstanding the provisions of paragraph 2 of this Article, interest arising in a Contracting State shall be exempt from tax in that State if it is received and really held by the Government or the National Bank of other 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 recipient and the beneficial owner of the royalties is the resident of the other Contracting State, the tax so charged shall not exceed 10% of the gross amount of the royalties.
