Armenia

Agreement between Armenia and Ukraine for the avoidance of double taxation dated 14 May 1996 entered into force on 19 November 1996 (ratified by the Law of Ukraine # 369 dated 13 September 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) 5 % of the gross amount of the dividends if the beneficial owner is a company which holds 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 a Contracting State shall be exempt from tax in that State if:

a) the beneficial owner of that interest is the Government of the other Contracting State or its political-administrative subdivision, or local authorities, or any other bodies of that Government, political-administrative subdivisions or local authorities;

b) the beneficial owner of that interest is the National Bank of Ukraine or the Central Bank of Armenia, or entity guaranteeing export or import loans, or other entities to which, according to the laws of the Contracting State, the relevant rights are delegated.

Article 12 (Royalties):

Paragraph 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State shall be taxable only in that other State if such resident is the beneficial owner of the royalties.