Moldova

Convention between Moldova and Ukraine for the avoidance of double taxation dated 29 August 1995 entered into force on 27 May 1996 (ratified by the Law of Ukraine # 134 dated 23 April 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 partnership), and this company 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, its local authority, or any agency or with the help of that Government or local authority.

Paragraph 9. Notwithstanding the provisions of Article 7 of this Convention and paragraph 2 of this Article interest arising in a Contracting State which is paid to and directly held by the resident of the other Contracting State shall be exempt from tax in the first-mentioned state if it is paid in respect of loan made, guaranteed or insured or in respect of any other debenture or credit, guaranteed or insured on behalf of the other Contracting State by authorised organ.

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 the tax so charged shall not exceed 10 % of the gross amount of the payments.