その他令和7年7月4日
日本国とウクライナ共和国との間の租税条約（関連企業及び配当金に関する規定）
号外p.27
号外p.27
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公告概要
Double Taxation Convention - Associated Enterprises and Dividends
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日本国とウクライナ共和国との間の租税条約（関連企業及び配当金に関する規定）
令和7年7月4日|p.27
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4. The provisions of paragraphs 1,2 and 3 shall also apply to profits from the
participation in a pool, a joint business or an international operating agency.
ARTICLE9
ASSOCIATED ENTERPRISES
1. Where
(a) an enterprise of a Contracting State participates directly or indirectly in
the management, control or capital of an enterprise of the other
Contracting State, or
(b) persons pate directly or indirectly or indirectly in the management,
control or capital of an enterprise of a Contracting State and an enterprise
of the other Contracting State,
and in either case conditions are made or imposed between the two enterprises in their
commercial or financial relations which differ from those which would be made between
independent enterprises, then any profits which would, but for those conditions, have
accrued to one of the enterprises, but, by reason of those conditions, have not so accrued,
may be included in the profits of that enterprise and taxed accordingly.
2. Where a Contracting State includes in the profits of an enterprise of that
Contracting State - and taxes accordingly - profits on which an enterprise of the other
Contracting State has been charged to tax in that other Contracting State and the profits
so included are profits which would have accrued to the enterprise of the first-mentioned
Contracting State if the conditions made between the two enterprises had been those
which would have been made between independent enterprises, then that other
Contracting State shall make an appropriate adjustment to the amount of the tax charged
therein on those profits. In determining such adjustment, due regard shall be had to the
other provisions of this Convention and the competent authorifies of the Contracting
States shall if necessary consult each other.
1.Dividends paid by a company which is a resident of a Contracting State to a
resident of the other Contracting State may be taxed in that other Contracting State.
2. However, dividends paid by a company which 1990.e e ce mpp aa coomicchhnyyy whhhiccchh.:0.0a resident of a Contracting State
may also be taxed in that Contracting State according to the laws of that Contracting State,
but if the beneficial owner of the dividends is a resident of the other Contracting State,
the tax so charged shall not exceed:
ARTICLE 10
DIVIDENDS
(a) 5 per cent of the gross amount of the dividends if the beneficial owner is
a company which has owned directly or indirectly, throughout a six month
period that includes the date on which entitlement to the dividends is
determined (for the purpose of computing that period, no account shall be
taken of changes of ownership that would directly result from a corporate
reorganisation, such as a merger or divisive reorganisation, of the company
that is the beneficial owner of the dividends or that pays the dividends), at
least 25 per cent of:
(i) in the case where the company paying the dividends is a resident
of Japan, the voting power of that company;
(ii) in the case where the company paying the dividends is a resident
of Ukraine, the capital of that company;
(b)15 per cent of the gross amount of the dividends in all other cases.
3. Notwithstanding the provisions of paragraph 2, where dividends paid by a
company which is a resident of a Contracting State are deductible in computing the
taxable income of that company in that Contracting State, such dividends may be taxed
in that Contracting State according to the laws of that Contracting State, but if the
beneficial owner of the dividends is a resident of the other Contracting State, the tax sc
charged shall not exceed 15 per cent of the gross amount of the dividends
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