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Belgium: Double Tax Treaties

Tax Treaty Agreements

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Belgium


Jurisdiction Status Dividends Interest Royalties Notes
           
Defaults 21% when paid on certain shares 25% 21% 15%
           
Albania Effective January 1, 2005 5% where the payee is a company holding directly at least 25% of the paying company's capital 15% 5% 5%
Algeria Effective January 1, 2004 15% 0% when paid on commercial debt claims resulting from payments for goods, merchandise or services, or on a bank loan or deposit not represented by bearer instruments 15% 5% for copyright royalties (excluding broadcasting royalties) 15%
Argentina Effective January 1, 2000 10% where the payee is a company holding at least 25% of the paying company's capital 15% 0% when paid to the government or the central bank, or on commercial debt-claims resulting from payments for machinery or equipment, or on a loan or credit guaranteed or insured by a financial institution to promote exports, or on a bank loan financed for at least three years not represented by bearer instruments 12% 3% for news royalties 5% for copyright royalties 10% 15% for broadcasting royalties
Armenia Effective January 1, 2005 5% where the payee is a company holding directly at least 10% of the paying company's capital 15% 0% when paid to the government, or on sales on credit of equipment or goods, or on a bank loan not represented by bearer instruments 10% 8%
Australia Effective January 1, 1980 15% 10% 10%
Austria Effective January 1, 1974 15% 0% when paid on commercial debt-claims resulting from payments for goods, merchandise or services, or on a bank deposit not represented by bearer instruments, or on current accounts or advances between banks 15% 0% 10% where the payee is a company holding more than 50% of the paying company's capital
Azerbaijan Effective January 1, 2007 5% where the payee is a company holding at least 30% of the paying company's capital with a minimum investment of USD500,000 or equivalent, or has invested a minimum of USD10m or equivalent 10% where the payee is a company holding at least 10% of the paying company's capital with a minimum investment of USD75,000 or equivalent 15% 0% when paid to the government, or on commercial debt-claims resulting from payments for goods, merchandise or services, or on a loan or credit financed, guaranteed or insured by the government to promote exports 10% 5% for literary or artistic copyrights or broadcasting royalties 10%
Bahrain Signed November 4, 2007 0% where the payee is a company holding directly at least 10% of the paying company's capital for 12 months before payment of the dividend 10% 0% when paid to the government or the central bank, or on commercial debt-claims resulting from payments for goods, merchandise or services, or on a loan or credit financed, guaranteed or insured by the government to promote exports, or on a bank loan or credit not represented by bearer instruments, or on a bank deposit 5% 0% Not yet in force. Default rates apply.
Bangladesh Effective January 1, 1998 15% 0% when paid on commercial debt-claims resulting from payments for goods, merchandise or services 15% 10%
Belarus Effective January 1, 1999 5% where the payee is a company holding at least 25% of the paying company's capital 15% 0% when paid on commercial debt-claims resulting from payments for equipment or services, or on a loan or credit financed, guaranteed or insured by a public entity to promote exports, or because of a transaction approved by Belgium 10% 5%
Bosnia and Herzegovina Effective January 1, 1984 10% where the payee is a company holding directly at least 25% of the paying company's capital 15% 15% 10% The Yugoslavia treaty continues to apply.
Brazil Effective January 1, 1974 Protocol effective January 1, 2008 10% where the payee is a company holding directly at least 10% of the paying company's capital 15% 0% when paid on a loan or credit financed by the government 10% when paid on a bank loan or credit granted for at least seven years in connection with the selling of goods or the design, installation or supply of industrial or scientific units and public works 15% 10% for copyright or broadcasting royalties 15% (3)
Bulgaria Effective January 1, 1992 10% 0% when paid to the government, or on commercial debt-claims resulting from payments for goods, merchandise or services, or on a loan, credit, current account or deposit not represented by bearer instruments 10% 5%
Canada Effective January 1, 2004 5% where the payee is a company holding directly at least 10% of the paying company's voting stock 15% 0% when paid to the government, or on a loan or credit financed, guaranteed or insured by a specified institution, or on sales on credit of equipment, merchandise or services 10% 0% for the use of any literary, artistic, dramatic or musical copyright (excluding broadcasting royalties), computer software or patent, or information concerning industrial, commercial or scientific experience (excluding a rental or franchise agreement) 10%
Chile Effective January 1, 2011 0% where the payee is a company holding directly at least 10% of the paying company's capital for 12 months before payment of the dividend 15% 5% when paid on a bank or insurance company loan, or on bonds or securities regularly traded on a recognised securities market, or on sales on credit of equipment or machinery 15% 5% for equipment royalties 10%
China Effective January 1, 2014 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital for 12 months before payment of the dividend 10% 0% when paid to the government or the central bank, or on a loan guaranteed or insured by the government or the central bank 10% 7%
Congo, Republic of the Effective January 1, 2012 5% where the payee is a company holding directly at least 25% of the paying company's capital 10% 0% when paid to the government or the central bank, or on commercial debt-claims resulting from payments for goods, merchandise or services, or on a bank loan or credit not represented by bearer instruments 10% 10%
Cote d'Ivoire Effective January 1, 1981 15% 16% 10%
Croatia Effective January 1, 2005 5% where the payee is a company holding at least 10% of the paying company's capital 15% 0% when paid to the government, or on commercial debt-claims resulting from payments for goods, merchandise or services, or on a loan or credit financed, guaranteed or insured by the government to promote exports, or on a bank loan or deposit not represented by bearer instruments 10% 0%
Cyprus Effective January 1, 2000 10% where the payee is a company holding at least 25% of the paying company's capital 15% 0% when paid to the government or the central bank, or on a bank deposit not represented by bearer instruments 10% 0%
Czech Republic Effective January 1, 2001 5% where the payee is a company holding at least 25% of the paying company's capital 15% 0% when paid to the government, or on commercial debt-claims resulting from payments for goods, merchandise or services, or on a loan or credit financed, guaranteed or insured by a public entity to promote exports, or on a bank loan or deposit not represented by bearer instruments 10% 5% for equipment royalties 10%
Denmark Effective January 1, 1971 Protocol effective January 1, 2004 0% where the payee is a company holding directly at least 25% of the paying company's capital 15% 0% when paid on commercial debt-claims resulting from payments for goods, merchandise or services, or on a bank deposit not represented by bearer instruments, or on current accounts or advances between banks 10% 0%
Ecuador Effective January 1, 2005 15% 0% when paid to the government, or on commercial debt-claims resulting from payments for goods, merchandise or services, or on a loan or credit financed, guaranteed or insured by a public entity to promote exports, or on a bank loan not represented by bearer instruments 10% 10%
Egypt Effective January 1, 1998 15% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 20% 15% 15% (3)
Estonia Effective January 1, 2004 5% where the payee is a company holding directly at least 25% of the paying company's capital 15% 0% when paid to the government or the central bank, or on a loan guaranteed or insured by the government, or on sales on credit of equipment or merchandise 10% 5% for equipment royalties 10%
Finland Effective January 1, 1979 Protocol effective January 1, 1990 5% where the payee is a company holding directly at least 25% of the paying company's capital 15% 0% when paid on commercial debt-claims resulting from payments for goods, merchandise or services, or on a bank deposit not represented by bearer instruments, or on current accounts or advances between banks, or as a penalty charge for late payments 10% 0% for copyright or broadcasting royalties 5%
France Effective September 17, 1965 Protocol effective January 1, 1970 10% where the payee is a company (excluding a partnership) holding at least 10% of the paying company's capital for 12 months before payment of the dividend 15% 15% 0%
Gabon Effective January 1, 2006 15% 0% when paid to the government, or on commercial debt-claims resulting from payments for goods, merchandise or services, or on current accounts or advances between banks 15% 10%
Georgia Effective January 1, 2005 5% where the payee is a company holding at least 25% of the paying company's capital 15% 0% when paid to the government, or on commercial debt-claims resulting from payments for goods, merchandise or services, or on a loan or credit financed, guaranteed or insured by a public entity to promote exports, or on a bank loan not represented by bearer instruments 10% 5%
Germany Effective January 1, 1966 15% 0% 15% when paid to a company holding at least 25% of the paying company's voting stock, or on bonds, debentures or securities 0%
Ghana Effective January 1, 2009 5% where the payee is a company holding directly at least 10% of the paying company's capital 15% 0% when paid to the government, or on commercial debt-claims resulting from payments for goods, merchandise or services, or on a loan or credit financed, guaranteed or insured by a public entity to promote exports 10% 10%
Greece Effective January 1, 2005 5% where the payee is a company holding at least 25% of the paying company's capital 15% 0% when paid to the government or the central bank 5% when paid on a bank loan not represented by bearer instruments 10% 5%
Hong Kong Effective January 1, 2004 0% where the payee is a company holding directly at least 25% of the paying company's capital for 12 months before payment of the dividend 5% where the payee is a company holding directly at least 10% of the paying company's capital 15% 0% when paid to the government, or on commercial debt-claims resulting from payments for goods, merchandise or services, or on a loan or credit financed, guaranteed or insured by the government to promote exports, or on a bank loan or credit not represented by bearer instruments, or on a bank deposit 10% 5%
Hungary Effective January 1, 1985 10% 0% when paid on commercial debt-claims resulting from payments for goods, merchandise or services, or on current accounts or advances between banks, or on a bank deposit not represented by bearer instruments 15% 0%
Iceland Effective January 1, 2004 5% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital 15% 0% when paid to the government, or on commercial debt-claims resulting from payments for goods, merchandise or services, or on a loan or credit financed, guaranteed or insured by a public entity to promote exports, or on a bank loan or deposit not represented by bearer instruments 10% 0%
India Effective January 1, 1998 15% 10% when paid on a bank loan 15% 15% (3)
Indonesia Effective January 1, 2002 10% where the payee is a company holding directly at least 25% of the paying company's capital 15% 0% when paid to the government or the central bank 10% 10%
Ireland Effective January 1, 1974 15% 0% when paid on commercial debt-claims resulting from payments for goods, merchandise or services, or on current accounts or advances between banks, or on a bank deposit not represented by bearer instruments 15% 0%
Isle of Man Signed July 16, 2009 0% where the payee is a company holding directly at least 10% of the paying company's capital for 12 months before payment of the dividend, or a pension fund 15% 0% when paid to the government or a pension fund, or on a loan or credit financed by a company, or on a loan or credit financed, guaranteed or insured by the government to promote exports 10% 0% Not yet in force. Default rates apply.
Israel Effective January 1, 1975 15% 0% when paid on current accounts or advances between banks 15% 0% for copyright royalties (excluding broadcasting royalties) 10%
Italy Effective January 1, 1990 15% 0% when paid to the government on a loan not represented by bearer instruments, or to a credit institution on a loan not represented by bearer instruments approved by both governments 10% 5%
Japan Effective January 1, 1970 Protocol effective January 1, 1991 5% where the payee is a company holding at least 25% of the paying company's voting stock for six months before payment of the dividend 15% 10% 10%
Kazakhstan Effective January 1, 2000 5% where the payee is a company holding at least 10% of the paying company's capital 15% 0% when paid to the government or the central bank, or on a loan or credit financed, guaranteed or insured by the government to promote exports 10% 10%
Korea, South Effective January 1, 1979 Protocol effective January 1, 1996 15% 0% when paid to the government or the central bank 10% 10%
Kuwait Effective January 1, 2001 0% where the payee is the government, the central bank or a company at least 25% owned by the government 10% 0% 10%
Kyrgyzstan Effective January 1, 1992 15% 0% when paid to the government, or on a loan guaranteed by the government, or on commercial debt-claims resulting from payments for goods, merchandise or services, or on a bank loan or deposit not represented by bearer instruments 15% 0% The USSR treaty continues to apply.
Latvia Effective January 1, 2004 5% where the payee is a company holding directly at least 25% of the paying company's capital 15% 0% when paid to the government or the central bank, or on a loan guaranteed or insured by the government, or on sales on credit of equipment or merchandise 10% 5% for equipment royalties 10%
Lithuania Effective January 1, 2004 5% where the payee is a company holding directly at least 25% of the paying company's capital 15% 0% when paid to the government or the central bank, or on a loan guaranteed or insured by the government, or on sales on credit of equipment or merchandise 10% 5% for equipment royalties 10%
Luxembourg Effective January 1, 1972 10% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital since the beginning of its financial year, or has invested a minimum of FR250m or equivalent (4) 15% 0% 15% when paid to a company holding at least 25% of the paying company's voting stock, or on bonds, debentures or securities 0%
Macau Signed June 19, 2006 0% where the payee is a company holding directly at least 25% of the paying company's capital for 12 months before payment of the dividend 5% where the payee is a company holding directly at least 10% of the paying company's capital 10% 0% when paid to the government, or on commercial debt-claims resulting from payments for goods, merchandise or services, or on a loan or credit financed, guaranteed or insured by the government to promote exports, or on a bank loan or credit not represented by bearer instruments, or on a bank deposit 10% 5% Not yet in force. Default rates apply.
Macedonia Effective January 1, 1984 New treaty signed July 6, 2010 10% where the payee is a company holding directly at least 25% of the paying company's capital 15% When new treaty is effective: 0% where the payee is a company holding at least 25% of the paying company's capital for 12 months before payment of the dividend 5% where the payee is a company holding directly at least 10% of the paying company's capital 15% 15% When new treaty is effective: 0% when paid to the government, or on a loan or credit financed by a company 10% 10% The Yugoslavia treaty continues to apply. New treaty not yet in force.
Malaysia Effective January 1, 1976 Protocol effective January 1, 1994 15% 0% when paid to the government or the central bank 10% 10%
Malta Effective January 1, 1977 Protocol effective January 1, 1993 15% 0% when paid to the government or the central bank, or on commercial debt-claims resulting from payments for goods, merchandise or services 10% 0% for copyright or broadcasting royalties 10%
Mauritius Effective January 1, 2000 5% where the payee is a company (excluding a partnership) holding at least 10% of the paying company's capital 10% 0% when paid to the government, or on commercial debt-claims resulting from payments for goods, merchandise or services, or on a loan or credit financed, guaranteed or insured by a public entity to promote exports, or on a bank loan or deposit not represented by bearer instruments 10% 0%
Mexico Effective January 1, 1998 5% where the payee is a company holding at least 25% of the paying company's capital 15% 0% when paid to the government, or on a loan or credit financed, guaranteed or insured for at least three years by a public entity to promote exports 10% when paid on a bank loan not represented by bearer instruments 15% 10%
Moldova Effective January 1, 1992 New treaty signed December 4, 2008 15% When new treaty is effective: 0% where the payee is a company holding at least 50% of the paying company's capital for 12 months before payment of the dividend and has invested a minimum of EUR1m or equivalent, or a pension fund 5% where the payee is a company holding at least 25% of the paying company's capital for 12 months before payment of the dividend 10% 0% when paid to the government, or on a loan guaranteed by the government, or on commercial debt-claims resulting from payments for goods, merchandise or services, or on a bank loan or deposit not represented by bearer instruments 15% When new treaty is effective: 0% when paid to the government, the central bank, a financial institution or a pension fund 5% 0% When new treaty is effective: 5% The USSR treaty continues to apply. New treaty not yet in force.
Mongolia Effective January 1, 2001 5% where the payee is a company holding at least 10% of the paying company's capital 15% 0% when paid to the government, or on commercial debt-claims resulting from payments for goods, merchandise or services, or on a loan or credit financed, guaranteed or insured by a public entity to promote exports, or on a bank loan or deposit not represented by bearer instruments 10% 5%
Morocco Effective January 1, 2010 6.5% where the payee is a company holding directly at least 25% of the paying company's capital 10% 0% when paid to the government or the central bank, or on a loan or credit guaranteed to promote exports 10% 10%
Netherlands Effective January 1, 2003 5% where the payee is a company holding directly at least 10% of the paying company's capital 15% 0% when paid to the government or the central bank, or on commercial debt-claims resulting from payments for goods, merchandise or services, or on a loan or credit financed, guaranteed or insured by the government to promote exports, or on a loan or deposit not represented by bearer instruments, or on a bank or insurance company loan or deposit represented by bearer instruments held for at least three months 10% 0%
New Zealand Effective January 1, 1984 15% 10% 10%
Nigeria Effective January 1, 1995 12.5% where the payee is a company holding at least 10% of the paying company's voting stock 15% 12.50% 12.50%
Norway Effective January 1, 1992 New treaty signed April 23, 2014 5% where the payee is a company holding directly at least 25% of the paying company's capital 15% When new treaty is effective: 0% where the payee is a company holding directly at least 10% of the paying company’s capital for 12 months before payment of the dividend, the government or the central bank 5% where the payee is a pension fund 15% 0% when paid to the government, or on commercial debt-claims resulting from payments for goods, merchandise or services, or on a bank loan not represented by bearer instruments 15% When new treaty is effective: 0% when paid to the government or a pension fund, or on sales on credit of equipment, merchandise or services, or on a bank loan not represented by bearer instruments, or on a loan or credit granted between enterprises 10% 0% New treaty not yet in force.
Oman Signed December 16, 2008 0% where the payee is the government, the central bank or a pension fund 5% where the payee is a company holding directly at least 10% of the paying company's capital 10% 0% when paid to the government, the central bank or a pension fund, or on commercial debt-claims resulting from payments for goods, merchandise or services, or on a loan or credit financed, guaranteed or insured by the government to promote exports, or on a bank loan or credit not represented by bearer instruments, or on a bank deposit 5% 8% Not yet in force. Default rates apply.
Pakistan Effective July 1, 1983 15% 0% when paid to the government or the central bank 15% 0% for literary, artistic, dramatic or musical copyright royalties (excluding broadcasting royalties) 15% (3)
Philippines Effective January 1, 1981 Protocol effective January 1, 2000 10% where the payee is a company holding directly at least 10% of the paying company's capital 15% 0% when paid on government bonds or debentures, or on a loan or credit financed, guaranteed or insured by a government approved institution 10% 15%
Poland Effective January 1, 2005 5% where the payee is a company (excluding a partnership) either holding directly at least 25% of the paying company's capital, or holding directly at least 10% of the paying company's capital with a value of at least EUR500,000 or equivalent 15% 0% when paid to the government, or on a bank loan not represented by bearer instruments, or on a loan or credit financed, guaranteed or insured by the government to promote exports 5% 5%
Portugal Effective January 1, 1972 Protocol effective January 1, 2002 15% 0% when paid on commercial debt-claims resulting from payments for goods, merchandise or services, or on current accounts or advances between banks 15% 10%
Qatar Signed November 6, 2007 0% where the payee is a company holding directly at least 10% of the paying company's capital 5% where the payee is a company holding directly at least 10% of the paying company's capital for 48 months before payment of the dividend 10% 0% when paid to the government or the central bank, or on commercial debt-claims resulting from payments for goods, merchandise or services, or on a loan or credit financed, guaranteed or insured by the government to promote exports, or on a bank deposit not represented by bearer instruments 5% 5% Not yet in force. Default rates apply.
Romania Effective January 1, 1999 5% where the payee is a company holding at least 25% of the paying company's capital 15% 0% when paid on a loan or credit financed, guaranteed or insured by the government 10% 5%
Russia Effective January 1, 2001 10% 0% when paid to the government, or on a loan or credit guaranteed or insured by the government, or on a bank loan not represented by bearer instruments 10% 0%
Rwanda Effective January 1, 2011 0% where the payee is a company holding directly at least 25% of the paying company's capital for 12 months before payment of the dividend 15% 0% when paid to the government or a company holding at least 35% of the paying company's capital, or on commercial debt-claims resulting from payments for goods, merchandise or services, or on a loan or credit financed, guaranteed or insured by the government to promote exports 10% 10%
San Marino Effective January 1, 2008 0% where the payee is a company holding directly at least 25% of the paying company's capital for 12 months before payment of the dividend 5% where the payee is a company holding directly at least 10% of the paying company's capital for 12 months before payment of the dividend 15% 0% when paid to the government, or on commercial debt-claims resulting from payments for goods, merchandise or services, or on a loan or credit financed, guaranteed or insured by the government to promote exports, or on a bank loan or credit not represented by bearer instruments, or on a bank deposit 10% 5%
Senegal Effective January 1, 1994 15% 15% 10%
Montenegro Effective January 1, 1984 10% where the payee is a company holding directly at least 25% of the paying company's capital 15% 15% 10% The Yugoslavia treaty continues to apply.
Seychelles Signed April 26, 2006 0% where the payee is a company holding directly at least 25% of the paying company's capital for 12 months before payment of the dividend 5% where the payee is a company holding directly at least 10% of the paying company's capital 15% 0% when paid to the government, or on a loan or credit financed, guaranteed or insured by the government to promote exports, or on a bank loan or credit not represented by bearer instruments, or on a bank deposit 5% when paid on commercial debt-claims resulting from payments for goods, merchandise or services 10% 5% Not yet in force. Default rates apply.
Singapore Effective January 1, 2009 0% where the payee is a company holding directly at least 25% of the paying company's capital for 12 months before payment of the dividend 5% where the payee is a company holding directly at least 10% of the paying company's capital 15% 0% when paid to the government, the central bank or between banks 5% 3% for equipment royalties 5%
Slovakia Effective January 1, 2001 5% where the payee is a company holding at least 25% of the paying company's capital 15% 0% when paid to the government, or on commercial debt-claims resulting from payments for goods, merchandise or services, or on a loan or credit financed, guaranteed or insured by a public entity to promote exports, or on a loan or current account not represented by bearer instruments between banks 10% 5%
Slovenia Effective January 1, 2003 5% where the payee is a company holding directly at least 25% of the paying company's capital 15% 0% when paid to the government, or on commercial debt-claims resulting from payments for goods, merchandise or services, or on a loan or credit financed, guaranteed or insured by a public entity to promote exports 10% 5%
South Africa Effective January 1, 1999 5% where the payee is a company holding at least 25% of the paying company's capital 15% 0% when paid to the government, or on commercial debt-claims resulting from payments for goods, merchandise or services, or on a loan or credit financed, guaranteed or insured by a public entity to promote exports, or on a bank loan or deposit not represented by bearer instruments 10% 0%
Spain Effective January 1, 1996 0% where the payee is a company holding directly at least 25% of the paying company's capital 15% 0% when paid on commercial debt-claims resulting from payments for equipment, goods, merchandise or services, or on a loan or credit financed, guaranteed or insured by a public entity to promote exports, or on current accounts or advances between banks 10% 5%
Sri Lanka Effective January 1, 1985 15% 0% when paid to the government 10% 10%
Sweden Effective January 1, 1991 5% where the payee is a company holding directly at least 25% of the paying company's capital 15% 0% when paid on commercial debt-claims resulting from payments for goods, merchandise or services, or on a bank loan or deposit not represented by bearer instruments 10% 0%
Switzerland Effective January 1, 1980 10% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% when paid on a bank loan not represented by bearer instruments, or on sales on credit of equipment or merchandise 10% 0%
Taiwan Effective January 1, 2006 10% 0% when paid to the government or the central bank, or on a loan between banks, or on a loan or credit financed, guaranteed or insured by the government to promote exports 10% 10%
Tajikistan Effective January 1, 1992 New treaty signed February 10, 2009 15% When new treaty is effective: 0% where the payee is a company holding directly at least 10% of the paying company's capital for 12 months before payment of the dividend, or a pension fund 15% 0% when paid to the government, or on a loan guaranteed by the government, or on commercial debt-claims resulting from payments for goods, merchandise or services, or on a bank loan or deposit not represented by bearer instruments 15% When new treaty is effective: 0% when paid to the government or a pension fund, or on a loan or credit financed by a company 10% 0% When new treaty is effective: 10% The USSR treaty continues to apply. New treaty not yet in force.
Thailand Effective January 1, 1980 15% where the payee is a company holding at least 25% of the paying company's voting stock 20% 0% when paid to the government or the central bank 10% when paid to a financial institution or insurance company 21% (3) 5% for copyright royalties (excluding broadcasting royalties) 15%
Tunisia Effective January 1, 2010 5% where the payee is a company holding directly at least 10% of the paying company's capital 15% 0% when paid on a loan or credit financed, guaranteed or insured by the government or the central bank 5% when paid on a bank loan not represented by bearer instruments 10% 11%
Turkey Effective January 1, 1992 15% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital 20% 0% when paid to the government or the central bank 15% 10%
Turkmenistan Effective January 1, 1992 15% 0% when paid to the government, or on a loan guaranteed by the government, or on commercial debt-claims resulting from payments for goods, merchandise or services, or on a bank loan or deposit not represented by bearer instruments 15% 0% The USSR treaty continues to apply.
Uganda Signed July 26, 2007 5% where the payee is a company holding directly at least 10% of the paying company's capital 15% 0% when paid to the government, or on a loan or credit financed, guaranteed or insured by the government to promote exports, or on a bank loan or credit not represented by bearer instruments 10% 10% Not yet in force. Default rates apply.
Ukraine Effective January 1, 2000 5% where the payee is a company holding directly at least 20% of the paying company's capital 15% 0% when paid to the government, or on a loan or credit financed, guaranteed or insured by a government institution to promote exports 2% when paid on a bank or financial institution loan not represented by bearer instruments, or on sales on credit of equipment, merchandise or services 10% 0% 10% for literary or artistic copyrights or broadcasting royalties
United Arab Emirates Effective January 1, 1995 0% where the payee is the government or a financial institution 5% where the payee is a company holding at least 25% of the paying company's capital 10% 0% when paid to the government or a financial institution 5% 0% when paid to the government or a financial institution 5%
United Kingdom Effective January 1, 1990 Protocol effective January 1, 2013 0% where the payee is a company holding directly at least 10% of the paying company's capital for 12 months before payment of the dividend, or a pension fund 10% 0% when paid to the government or a pension fund, or on a loan or credit financed between companies 10% 0%
United States Effective February 1, 2008 0% where the payee is a company holding directly at least 10% of the paying company's capital for 12 months before the dividend is declared, or a pension fund 5% where the payee is a company holding directly at least 10% of the paying company's voting stock 15% 0% 0% Separate dividend withholding tax rules apply to REITs.
Uruguay Signed August 23, 2013 0% where the payee is a pension fund 5% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital 15% 0% when paid to the government or a pension fund 10% 10% Not yet in force. Default rates apply.
Uzbekistan Effective January 1, 2000 5% where the payee is a company holding directly at least 10% of the paying company's capital 15% 0% when paid to the government, or on commercial debt-claims resulting from payments for goods, merchandise or services, or on a loan or credit financed, guaranteed or insured by a public entity to promote exports 10% 5%
Venezuela Effective January 1, 1999 5% where the payee is a company holding at least 25% of the paying company's capital 15% 0% when paid to the government, or on commercial debt-claims resulting from payments for goods, merchandise or services, or on a loan or credit financed, guaranteed or insured by a public entity to promote exports, or on a bank deposit not represented by bearer instruments 10% 5%
Vietnam Effective January 1, 2000 5% where the payee is a company holding at least 50% of the paying company's capital 10% where the payee is a company holding at least 25% of the paying company's capital 15% 0% when paid to the government or the central bank 10% 5% for the use of any patent, design or model, plan, secret formula or process, or information concerning industrial or scientific experiences 10% for the use of any trademark or information concerning commercial experience 15%
Serbia Effective January 1, 1984 10% where the payee is a company holding directly at least 25% of the paying company's capital 15% 15% 10% The Yugoslavia treaty continues to apply.

Footnotes

  1. In the case of European Union countries, the EC Parent-Subsidiary Directive can reduce dividend withholding tax to 0%, subject to certain conditions.
  2. In the case of European Union countries, the EC Interest and Royalties Directive can reduce interest and royalties withholding tax to 0%, subject to certain conditions.
  3. The treaty specifies a different rate but the default rate is lower and would therefore apply.
  4. The currency stated in the treaty has been replaced by the Euro and should be calculated as such.
  5. PLEASE NOTE: This table was last updated February 2015

 

 

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