United Kingdom

Convention between the UK and Ukraine for the avoidance of double taxation dated 10 February 1993 entered into force on 11 August 1993.

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 and subject to tax in respect of the dividends in that 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 which controls, directly or indirectly, in the case of the United Kingdom, at least 20% of the voting power in the company paying the dividends and in the case of Ukraine at least 20% of the authorised capital in the company paying the dividends;

(b) 10% of the gross amount of the dividends in all other cases.

Article 11 (Interest):

Paragraph 1. Interest arising in a Contracting State and paid to a resident of the other Contracting State shall be taxable only in that other State if such resident is the beneficial owner of the interest and subject to tax in respect of the interest in that other Contracting State.

Article 12 (Royalties):

Paragraph 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State shall be taxable only in that other State if such resident is the beneficial owner of the royalties and is subject to tax in respect of the royalties in that other Contracting State.