Convention between Romania and Ukraine for the avoidance of double taxation dated 29 March 1996 entered into force on 17 November 1997 (ratified by the Law of Ukraine # 586 dated 21 October 1997).
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) 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 % 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 3. Notwithstanding the provisions of paragraph 2 of this Article, interest arising in Contracting State shall be exempt from the tax in that State if paid on debt-claim of the Government of the other Contracting State, its National (Central) Bank or any other bank or institution, authorised to make, guarantee or insure credits on behalf of the Government of the other 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 is the beneficial owner of the royalties the tax so charged shall not exceed:
(a) 10 % of the gross amount of the royalties for the use of or the right to use any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience;
(b) 15 % of the gross amount of the royalties in all other case.
