Indonesia

Agreement between Indonesia and Ukraine for the avoidance of double taxation dated 11 April 1996 entered into force on 9 November 1998 (ratified by the Law of Ukraine # 432 dated 29 October 1996).

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 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 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 received the Government of the other Contracting State including political-administrative subdivision, local authorities, Central Bank (for Ukraine - the National Bank of Ukraine, for Indonesia - Bank of Indonesia) shall be exempt from tax in the first-mentioned State.

Paragraph 4. Notwithstanding the provisions of paragraph 2 of this Article, interest arising in a Contracting State and paid to the resident of the other Contracting State shall be exempt from tax in that State if it is paid in respect of loan guaranteed by the Government of the other Contracting State.

Article 12 (Royalties):

Paragraph 2. Rate of tax collected in the first Contracting State in which arise royalties received from sources in that Contracting State and which are beneficially owned by the resident of the other Contracting State shall not exceed 10% of the gross amount of royalties.


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