Macedonia

Convention between Macedonia and Ukraine for the avoidance of double taxation dated 2 March 1998 entered into force on 23 November 1998 (ratified by the Law of Ukraine # 232 dated 5 November 1998).

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) 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 8. 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 and really held by the Government of the other Contracting State, or political-administrative subdivisions and local authorities thereof, or the National Bank of that other Contracting State, or bank wholly owned by the Government of the other Contracting State. In the same manner interest arising in a Contracting State shall be exempt from tax in that State if such interest is paid in respect of loan guaranteed by the Government of the other Contracting 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 10 % of the gross amount of the royalties.