Tax Treaties: November 2009

China - Czech Republic Tax Treaty – Tax treaty signed 28 August 2009, once in effect, will provide for a 5% tax rate on dividends paid to a company (other than a partnership) that holds directly at least 25% of the capital of the company paying the dividends; otherwise, the tax rate will be 10%. The withholding tax rates on interest and royalties will be 7.5% and 10%, respectively.

Denmark - Israel Tax Treaty – Tax treaty signed 9 September 2009, once in effect, will provide a 10% general rate on dividends, with government and pension-related exemptions, as well as an exemption where the dividends are paid to a company (other than a partnership) that holds directly at least 10% of the distributing company's capital for an uninterrupted period of no less than one year, with the dividends declared within that period. Interest will be subject to a 5% rate, with exemptions provided for pensions, qualifying corporate bonds and certain government-related interest. Royalties will be tax exempt.

Ireland - Bahrain Tax Treaty – The tax treaty signed 29 October 2009, once in effect, will exempt dividends, interest and royalties from withholding tax in the source state.

Ireland - Belarus Tax Treaty – The tax treaty signed 3 November 2009 will, once in effect, provide for a 5% withholding tax rate on dividends where the beneficial owner is a company (other than a partnership) that holds directly at least 25% of the capital of the distributing company; otherwise, the rate will be 10% (with certain government-related exemptions). Interest and royalties will be subject to a 5% withholding tax rate (with government-related exemptions for interest and an exemption where interest is paid on the acquisition of industrial, trade, medical or scientific equipment).

Ireland - Bosnia and Herzegovina Tax Treaty – The tax treaty signed 3 November 2009, once in effect, will exempt dividends, interest and royalties from withholding tax in the source state.

Latvia - Tajikistan Tax Treaty – Tax treaty signed in February 2009 entered into force on 29 October 2009 and will generally apply as from 1 January 2010. Once in effect, the treaty provides for a 0% rate on dividends paid to a company (other than a partnership) that directly holds at least 75% of the distributing company's capital; a 5% rate where the dividends are paid to a company (other than a partnership) that directly holds at least 25% of the distributing company's capital; and 10% in all other cases. The rate on interest will be 7%. A 5% tax rate will apply to royalties paid for the use of, or the right to use, software or industrial, commercial or scientific equipment, and 10% in all other cases.

Netherlands - Oman Tax Treaty – The tax treaty signed 5 October 2009, once in effect, will provide for a 0% rate on dividends paid to a company that directly holds at least 10% of the distributing company, and 10% in all other cases. Interest will be taxable only in the state of residence. Royalties will be taxed at a rate of 8%.

Singapore - Georgia Tax Treaty – The treaty signed 17 November 2009, once in effect, will exempt dividends, interest and royalties from withholding tax in the source state.