Turkey

Agreement between Turkey and Ukraine for the avoidance of double taxation dated 27 November 1996 entered into force on 29 April 1998 (ratified by the Law of Ukraine # 37 dated 16 January 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) 10 % 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 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) Ukraine and paid to the Government of Turkey or to its local authorities or to the Central Bank of Turkey shall be exempt from Ukrainian tax;

(b) Turkey and paid to the Government of Ukraine or to its political subdivisions or its local authorities or to the National Bank of Ukraine shall be exempt from Turkish tax.

Article 12 (Royalties):

Paragraph 2. Royalties may be taxed in the Contracting State in which they arise and in accordance with the laws of that State, but the tax so charged shall not exceed 10 % of the gross amount of all payments.