Norway

Convention between Norway and Ukraine for the avoidance of double taxation dated 7 March 1996 entered into force on 18 September 1996 (ratified by the Law of Ukraine # 340 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 beneficial owner of the dividends is a resident of the other Contracting State, 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 directly 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 beneficial owner of the interest is a resident of the other Contracting State, 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 interest is paid in respect of a bond, debt-claim or other similar obligation of the government of the Contracting State or of a political subdivision or local authority thereof, provided that the interest is beneficially owned by a resident of the other Contracting State;

(b) the interest is paid from a debtor resident in Ukraine to a resident of Norway in respect of a loan made, guaranteed or insured, or a credit extended, guaranteed or insured by the Norwegian Guarantee Institute for Export Credits or A/S Eksportfinans or any other similar institution as may be agreed from time to time between the competent authorities of the Contracting States;

(c) the interest is paid from a debtor resident in Norway to a resident of Ukraine in respect of a loan made, guaranteed or insured, or a credit extended, guaranteed or insured by the government or National Bank of Ukraine or any other institutions similar to those mentioned in sub-paragraph (b) of this paragraph as may be agreed from time to time between the competent authorities of the Contracting States;

(d) the interest is paid by a purchaser to a seller in connection with a commercial credit resulting from deferred payments for goods, merchandise, equipment or services, except where the sale or indebtedness is between associated persons or enterprises in the sense of Article 9.

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 beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed:

(a) 5 % of the gross amount of the royalties paid for the use or the right to use any patent, plan, secret formula or process, or for information (know-how) concerning industrial, commercial or scientific experience;

(b) 10 % in all other cases.