It is understood that interest, wages and salaries paid by an enterprise carried on by a company that is a resident of Ukraine shall be deductible in computing the taxable profits of such enterprise, provided that a resident or residents of the Netherlands own or control, directly or indirectly, at least 20 per cent of the capital of such enterprise and provided that the payments of interest, wages and salaries do not relate to profits which are exempt from tax.
It is further understood that in the case of interest, wages and salaries borne by a permanent establishment of an enterprise carried on by a resident of the Netherlands in Ukraine, or borne by a fixed base of a resident of the Netherlands in Ukraine, such interest, wages and salaries shall be deductible in the determination of the taxable profits of such permanent establishment or in the determination of the taxable income of such fixed base, unless the interest, wages and salaries relate to profits which are exempt from tax.
