Italy

Convention between Italy and Ukraine for the avoidance of double taxation dated 26 February 1997 entered into force on 25 February 2003 (ratified by the Law of Ukraine # 502 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 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 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 shall be exempt from tax in that State if:

(a) the payer of the interest is the Government of that Contracting State or a local authority thereof; or

(b) the interest is paid to the Government of the other Contracting State or local authority thereof or any agency or instrumentality (including a financial institution) wholly owned by that other Contracting State or local authority thereof; or

(c) the interest is paid to any other agency or instrumentality (including a financial institution) in relation to loans made in application of an agreement concluded between the Governments of the Contracting States.

Article 12 (Royalties):

Paragraph 2. Royalties may be taxed in the Contracting State in which they arise and according with the laws of that State, but if the recipient is the beneficial owner of the royalties, the tax so charged shall not exceed 7 % of the gross amount of the royalties.