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TAX NEWS - January 2010

Bilateral Tax treaties in effect as from 1 January 2022

The table below reflects treaties that have entered into effect on 1 January 2022 with respect to their provisions on withholding taxes. Rates shown are as provided in the tax treaty - domestic withholding tax rates or other agreements (e.g. the EC directives) may provide a lower tax rate. The table does not include standard tax exemptions or reduced tax rates typically provided for interest paid to government entities, sales on credit, loans by banks, government-related loans, and similar payments.



Tax Treaty  /  Dividends  /  Interest  /  Royalties


Australia - France 0/5/15 10 5
The 0% tax rate applies on dividends where the recipient holds directly at least 10% of the voting power of the payer company and the dividends are paid out of profits that have borne the normal rate of company tax. The tax rate is 5% where the recipient is the beneficial owner and the above ownership requirements are met; otherwise, the tax rate is 15%.


Austria - Greece 5/15 8 7
The 5% tax rate applies on dividends paid to a company (other than a partnership) that holds directly at least 25% of the payer; the tax rate is 15% in all other cases.


Austria - Turkey 5/15 10/15 10
The 5% dividend tax rate applies on dividends paid to a company (other than a partnership) that holds directly at least 25% of the capital of the payer company; otherwise, the tax rate is 15%. The 10% tax rate applies to interest derived from a bank; the tax rate in all other cases is 15%.


Belgium - Morocco 6.5/10 10 10
The 6.5% tax rate applies on dividends paid to a company that holds at least 25% of the capital of the payer; otherwise, the tax rate is 10%.


Belgium - Tunisia 5/15 5/10 11
The 5% withholding tax applies on dividends paid to a company that holds directly at least 10% of the payer; otherwise, the tax rate is 15%. The tax rate on interest is 5% on bank loans not represented by bearer instruments; otherwise, the tax rate is 10%.


Brazil - Peru 10/15 15 15
The 10% tax rate applies on dividends paid to a company that holds directly at least 20% of the capital paying the dividends; otherwise, the tax rate is 15%.


Brazil - Russia 10/15 15 15
The 10% tax rate applies on dividends where the beneficial owner is a company that holds directly at least 20% of the capital of the payer company; otherwise, the tax rate is 15%.


China - Nigeria 7.5 7.5 7.5


China - Tajikistan 5/10 8 8
The 5% tax rate applies on dividends paid to a company (excluding a partnership) that holds at least 25% of the capital of the payer company; otherwise, the tax rate is 10%.


Cyprus - Czech Republic 0/5 0 10
The 0% tax rate applies on dividends paid to a company (other than a partnership) that holds directly at least 10% of the capital of the company paying the dividends and where the participation has been held for an uninterrupted period of no less than one year; otherwise, the tax rate is 5%. The treaty also allows the source state to impose a 10% withholding tax rate on royalty payments relating to a patent, trademark, design or model, plan, secret formula or process, computer software, or industrial, commercial or scientific equipment or for information concerning industrial, commercial or scientific experience. Royalties paid on a copyright of literary, artistic or scientific works, including cinematograph films and films or tapes for television or radio broadcasting, may be taxed in the recipient's state of residence.


Cyprus - Qatar 0 0 5


Czech Republic - Armenia 10 5 5/10
The 5% tax rate applies on royalties paid for copyrights of literary, artistic or scientific works (including cinematograph films and films or tapes for television or radio broadcasting); otherwise, the tax rate is 10%.


Czech Republic - Syria 10 10 12


Denmark - Croatia 5/10 5 10
The 5% tax rate applies 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 and the recipient has held the participation for at least one year and the dividends are declared within that period (see, however, changes discussed to Denmark's withholding tax regime under the "In brief" column). The 5% tax rate also applies where the beneficial owner is a pension fund or similar institution providing pension schemes in which individuals may participate to secure retirement benefits, provided the pension fund or similar institution is established, recognized for tax purposes and controlled in accordance with the laws of the other contracting state. Otherwise, the tax rate on dividends is 10%.


Denmark - Serbia 5/15 10 10
The 5% tax rate applies on dividends paid to a company other than a partnership) that holds directly at least 25% of the capital of the payer; otherwise, the tax rate is 15%.


Estonia - Isle of Man 0 0 0


Estonia - Israel 0/5 5 0
A withholding tax exemption is provided for certain government and pension related dividends and where the beneficial owner is a company (other than a partnership) that holds directly at least 10% of the capital of the distributing company; otherwise, the tax rate is 5%.


Estonia - Macedonia 0/5 5 5
The 0% tax rate applies on dividends paid to a company that holds directly at least 25% of the capital of the payer company; otherwise, the tax rate is 5%.


France - United Kingdom 0/15 0 0
The treaty applies in France as from 1 January 2010, but in the U.K. as from 1 April 2010. The 0% tax rate applies on dividends where the beneficial owner is a company that owns at least 10% of the dividend-paying company; otherwise, the tax rate is 15%.


Hungary - Uzbekistan 10 10 10


India - Tajikistan 5/10 10 10
The 5% tax rate applies on dividends paid to a company (other than a partnership) that holds directly at least 25% of the capital of the payer; otherwise, the tax rate is 10%.


Indonesia - Switzerland 10/15 10 10
The 10% tax rate applies on dividends if the beneficial owner is a company (other than a partnership) that directly holds at least 25% of the capital of the company paying the dividends; otherwise the tax rate is 15%. The protocol reduced withholding tax on royalties from 12.5% to 10%.


Ireland - Macedonia 5/10 0 0
The 5% tax rate applies on dividends paid to a company that holds at least 10% of the voting power or the company paying the dividends; otherwise, the tax rate is 10%.


Ireland - Malta 5/15 0 5
See notes under Malta article, above.


Italy - Belarus 5/15 8 6
The 5% tax rate applies on dividends if the beneficial owner is 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 is 15%.


Italy - Croatia 15 10 5


Italy - Saudi Arabia 5/10 5 10
The 5% tax rate applies on dividends if the beneficial owner is a company (other than a partnership) that has directly or indirectly owned at least 25% of the capital of the company paying the dividends for at least 12 months preceding the date the dividends were declared; otherwise, the tax rate is 10%.


Japan - Brunei 5/10 10 10
The 5% tax rate applies where the beneficial owner is a company that holds directly or indirectly at least 10% of the voting shares of the company paying the dividends for the six-month period ending on the date entitlement to the dividends is determined; otherwise, the tax rate is 10%.


Japan - Kazakhstan 5/15 10 5
The 5% tax rate applies where the beneficial owner is a company that holds directly or indirectly at least 10% of the voting shares of the payer company for the six-month period ending on the date entitlement to the dividends is determined; otherwise, the tax rate is 15%.


Korea - Qatar 11 11 11


Latvia - Morocco 6/10 10 10
The 6% tax rate applies on dividends paid where the beneficial owner is a company (not a partnership) that directly holds at least 25% of the capital of the payer company; otherwise, the tax rate is 10%.


Latvia - Tajikistan 0/5/10 7 5/10
The 0% tax rate applies on dividends paid to a company (other than a partnership) that directly holds at least 75% of the capital of the payer company. The 5% tax rate applies on dividends paid to a company (other than a partnership) that directly holds at least 25% of the capital of the distributing company. Otherwise, the tax rate is 10%. The 5% tax rate applies to royalties paid for the use of, or the right to use, software or industrial, commercial or scientific equipment; otherwise, the tax rate is 10%.


Lithuania - Serbia 5/10 10 10
The 5% tax rate applies on dividends paid to a company (other than a partnership) that holds directly at least 25% of the capital of the payer company; otherwise, the tax rate is 10%.


Luxembourg - Azerbaijan 5/10 10 5/10
The 5% tax rate applies on dividends paid to a company that owns at least 30% of the paying company and is capitalized with at least USD 300,000; otherwise, the tax rate is 10%. The 5% tax rate applies on royalties paid for patents, trademarks, designs, models, plans, secret formulas on information relating to industrial, commercial or scientific experience of less than three years; otherwise, the tax rate is 10%.


Luxembourg - Georgia 0/5/10 0 0
The 0% tax rate applies on dividends paid to a company that owns at least 50% of the distributing subsidiary and the value of the investment exceeds EUR 2 million or the equivalent in Georgian currency. The 5% tax rate applies where dividends are paid to a company that holds 10% of the payer and the value of the investment is EUR 100,000 or its equivalent in Georgian currency. Otherwise, the tax rate is 10%.


Luxembourg - India 10 10 10
In India, the treaty applies as from 1 April 2010.


Luxembourg - Moldova 5/10 5 5
The 5% tax rate applies on dividends where the beneficial owner is a company (other than a partnership) that holds directly at least 20% of the capital of the payer company; otherwise, the tax rate is 10%.


Luxembourg - United Arab Emirates 5/10 0 0
The 5% tax rate applies on dividends where the beneficial owner is a company (other than a partnership) that holds at least 10% of the capital of the payer; otherwise, the tax rate is 10%.


Malaysia - Qatar 5/10 5 8
The treaty does not apply in Malaysia for petroleum income tax purposes until 1 January 2011. The 5% tax rate applies on dividends if the beneficial owner is an individual or company (other than a partnership) that holds directly at least 10% of the capital of the payer company; otherwise, the tax rate is 10%.


Malta - Montenegro 5/10 10 10
See notes under Malta article, above.


Malta - Singapore 0 7/10 10
See notes under Malta article, above.


Mexico - Barbados 5/10 10 10
The 5% tax rate applies on dividends where the beneficial owner is a company that holds at least 10% of the capital of the payer company; otherwise, the tax rate is 10%.


Mexico - Netherlands 5/15 5/10 10
The 5% tax rate applies on dividends if the beneficial owner is a company that directly or indirectly holds at least 10% of the capital of the payer; otherwise the tax rate is 15%. The protocol reduced the applicable tax rates on interest and royalties. The 5% tax rate applies on interest on loans by a bank or financial institution and on bonds and debentures traded regularly on a recognized stock market, otherwise the tax rate is 10%.


Netherlands - Azerbaijan 5/10 0/10 5/10
The 5% tax rate applies where dividends are paid to a company that holds 25% of the payer company; otherwise, the tax rate is 10%. The tax rate on interest is generally 10%. The 5% tax rate applies on royalties paid in respect of a patent, design or model, plan, secret formula or process or information concerning industrial, commercial or scientific experience, if the patent, design or model, plan, secret formula or process or this information concerning industrial, commercial or scientific experience is not older than three years; otherwise, the tax rate is 10%.


Netherlands - Bahrain 0/10 0 0
The 0% tax rate applies where dividends are paid to a company that holds directly 10% of the payer company; however, if the taxation in Bahrain will result in a tax burden of less than 10% of the dividends, the Netherlands may impose a 10% tax (exceptions are provided for certain dividends). The tax rate in all other cases is 10%.


Netherlands - Qatar 0/10 0 5
The 0% tax rate applies where dividends are paid to a company that holds at least 7.5% of the capital of the payer company; otherwise, the tax rate is 10%.


Norway - Qatar 5/15 0 5
The 5% tax rate applies where dividends are paid to a company that holds directly at least 10% of the capital of the payer company; otherwise, the tax rate is 15%.


Norway - Slovenia 0/15 5 5
The 0% tax rate applies where dividends are paid to a beneficial owner that is a resident of Norway who is a partner in a Norwegian partnership and along or together with other such partners directly holds at least 15% of the capital of the payer company; otherwise, the tax rate is 15%.


Poland - Qatar 5 5 5


Portugal - Mozambique 10 10 10
The protocol reduced the withholding tax on dividends from 15% to 10%. The royalties article also was amended to provide that royalties include payments for technical assistance related to the use, or the granting of use, of rights, property or information as described in the royalty article.


Romania - Syria 5/15 11 12
The 5% tax rate applies on dividends paid to a company that holds directly at least 25% of the capital of the payer; otherwise, the tax rate is 15%.


Romania - Turkmenistan 10 10 15


Russia - Singapore 5/10 7.5 7.5
The 5% tax rate applies where dividends are paid to the government of the other contracting state or a company that holds directly at least 15% of the capital of the payer company and has invested in the distributing company at least USD 100,000 or its equivalent in another currency; otherwise, the tax rate is 10%.


Russia - Thailand 15 10/D 15
Interest will be subject to a 10% withholding tax rate if the beneficial owner, in the case of a resident of Russia, is an institution that has a license to carry on banking operations, and, in the case of a resident of Thailand, an financial institution (to include insurance companies); otherwise, the domestic rate applies.


Russia - Venezuela 10/15 5/10 10/15
The 10% tax rate applies to dividends paid to a company that holds at least 10% of the capital of the company paying the dividends and has invested at least USD 100,000 in the company; otherwise, the tax rate is 15%. The 5% tax rate applies to interest paid to banks; otherwise, the tax rate is 10%. The 15% tax rate applies to royalties generally, with the 10% tax rate applying to technical service fees.


Singapore - Belgium 0/5/15 5 3/5
The agreement has applied in Belgium as from 1 January 2009. The 0% tax rate applies where dividends are paid to a company that holds directly at the time the dividends are paid at least 25% of the capital of the payer company for an uninterrupted period of at least 12 months, shares representing directly at least 25% of the capital of the paying company. The 5% tax rate applies where the dividends are paid to a company holding directly at least 10% of the capital of the payer company. Otherwise, the tax rate is 15%. The 5% tax rate on royalties generally applies "on gross" for payments of any kind received for the use of, or the right to use, a copyright of literary, artistic or scientific work including computer software, cinematograph films, and films or tapes for radio or television broadcasting, a patent, trademark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience. The 5% tax rate applies on 60% of the gross payment (i.e. the "adjusted amount", resulting in a 3% effective tax rate of withholding) for the use of, or the right to use, industrial, commercial or scientific equipment.


Slovakia - Vietnam 5/10 10 5/10/15
The 5% tax rate applies on dividends paid to a company that holds directly at least 70% of the voting power of the distributing company; otherwise, the tax rate is 10%. The 5% tax rate applies to royalties paid for the use of, or the right to use, a patent, design or model, plan, secret formula or process, or for information concerning industrial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipment. The tax rate is 10% on royalties paid for the use of, or the right to use, a trademark or for information concerning commercial experience. Otherwise, the tax rate is 15%.


Slovenia - Albania 5/10 7 7
The 5% tax rate applies where dividends are paid to a company that holds directly at least 25% of the company paying the dividends; otherwise, the tax rate is 10%. The treaties information exchange provisions apply as from 4 May 2009.


South Africa - Switzerland 5/15 5 0
The 5% tax rate applies where dividends are paid to a company that holds at least 20% of the capital of the payer; otherwise, the tax rate is 15%.


Spain - El Salvador 0/12 10 10
The 0% tax rate applies where dividends are paid to a company that holds directly at least 50% of the capital of the payer and the payer has been taxed on the profits out of which the dividends are paid; otherwise, the tax rate is 12%.


Spain - Jamaica 5/10 10 10
The 5% tax rate applies to dividends paid to a company (other than a partnership) that holds directly or indirectly at least 25% of the capital of the company paying the dividends; otherwise, the tax rate is 10%.


Spain - Moldova 0/5/10 5 8
The 0% tax rate applies to dividends paid to a company (other than a partnership) that owns at least 50% of the payer company; the 5% tax rate applies where the dividends are paid to a company (other than a partnership) that holds at least 25% of the payer; otherwise, the tax rate is 10%.


Spain - Trinidad & Tobago 0/5/10 8 5
The 0% tax rate applies on dividends if the beneficial owner directly holds at least 50% of the capital of the payer company. The 5% tax rate applies where dividends are paid to a company that holds directly at least 25% of the capital of the payer company. Otherwise, the tax rate is 10%.


Switzerland - Algeria 5/15 10 10
The 5% applies where dividends are paid to a company (other than a partnership) that holds at least 20% of the capital of the dividend-paying company; otherwise, the tax rate is 15%.


Switzerland - Bangladesh 10/15 10 10
The 10% tax rate applies where dividends are paid to a company (other than a partnership) that directly holds at least 20% of the capital of the distributing company; otherwise, the tax rate is 15%.


Switzerland - Ghana 5/15 10 8
The 5% tax rate applies where dividends are paid to a company that holds directly at least 10% of the capital of the payer; otherwise, the tax rate is 15%.


Turkey - Saudi Arabia 5/10 10 10
The 5% tax rate applies where dividends are paid to a company (other than a partnership) that holds directly at least 20% of the capital of the payer company; otherwise, the tax rate is 10%.


Ukraine - Morocco 10 10 10


Ukraine - Singapore 5/15 10 7.5
The tax treaty does not enter into effect for Singapore until 1 January 2011. The 5% tax rate applies on dividends if the beneficial owner is a company (other than a partnership) that holds directly at least 20% of the capital of the company paying the dividends; otherwise, the tax rate is 15%.


Venezuela - Belarus 5/15 5 5/10
The 5% tax rate applies where dividends are paid to a company that holds at least 25% of the capital of the payer; otherwise, the tax rate is 15%. The 5% tax rate applies to royalties paid for the use of patents, trademarks, computer software or equipment and means of transport; all other royalties are subject to a 10% withholding tax.


Vietnam - Hong Kong 10 10 7/10
In Hong Kong, the treaty applies as from 1 April 2010. The 7% tax rate applies if royalties are made for the use of, or the right to use, a patent, design or model, plan, secret formula or process; otherwise, the tax rate is 10%.
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