China

Agreement between China and Ukraine for the avoidance of double taxation dated 4 December 1995 entered into force on 18 October 1996 (ratified by the Law of Ukraine # 342 dated 12 July 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 (other than a partnership) which holds at least 25 % of the capital of the company paying the dividends;

(b) 10 % 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 it is received by the Government of the other Contracting State, its political-administrative subdivision, local authority and Central Bank or any financial body that performs functions of the Government and wholly belongs to this Government.

Article 12 (Royalties):

Paragraph 2. Royalties 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 royalties, the tax so charged shall not exceed 10 % of the gross amount of the royalties.