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China: Double Tax Treaties

Table of Treaty Rates

Provided by TreatyPro
China


Jurisdiction Status Dividends Interest Royalties Notes
           
Defaults 10% 10% 10%
           
Albania Effective January 1, 2006 10% 0% when paid to the government or the central bank 10% 10%
Algeria Effective January 1, 2008 5% where the payee is a company (excluding a partnership) 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 financed by the government or the central bank 7% 10%
Armenia Effective January 1, 1997 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 10% 0% when paid to the government or the central bank 10% 10%
Australia Effective January 1, 1991 10% (1) 10% 10%
Austria Effective January 1, 1993 7% where the payee is a company holding directly at least 25% of the paying company's voting stock 10% 0% when paid to the government or the central bank 10% 10%
Azerbaijan Effective January 1, 2006 10% 0% when paid to the government or the central bank, or on a loan guaranteed by the government or the central bank 10% 10%
Bahrain Effective January 1, 2003 5% 0% when paid to the government or the central bank, or on a loan or credit indirectly financed by the government or the central bank 5% 10%
Bangladesh Effective January 1, 1998 10% 0% when paid to the government or the central bank, or on a loan or credit indirectly financed by the government or the central bank 10% 10%
Barbados Effective January 1, 2001 Protocol effective January 1, 2011 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 10% 0% when paid to the government or the central bank 10% 10%
Belarus Effective January 1, 1997 10% 0% when paid to the government or the central bank 10% 10%
Belgium 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%
Bosnia and Herzegovina Effective January 1, 1998 5% 0% when paid to the government or the central bank 10% 10% The Yugoslavia treaty continues to apply.
Botswana Signed April 11, 2012 5% 0% when paid to the government or the central bank, or on a loan guaranteed or insured by the government or the central bank 7.5% 5% Not yet in force. Default rates apply.
Brazil Effective January 1, 1994 10% (1) 0% when paid to the government or the central bank, or on government bonds, securities or debentures 10% (1) 10% (1)
Brunei Effective January 1, 2007 5% 0% when paid to the government or the central bank 10% 10%
Bulgaria Effective January 1, 1991 10% 0% when paid to the government or the central bank, or on a loan or credit indirectly financed by the government or the central bank 10% 7% for equipment royalties 10%
Canada Effective January 1, 1987 10% (1) 0% when paid to the government or the central bank, or on a loan financed or guaranteed by a specified institution 10% 10%
Croatia Effective January 1, 2002 5% 0% when paid to the government or the central bank, or on a loan or credit indirectly financed by the government or the central bank 10% 10%
Cuba Effective January 1, 2004 5% where the payee is a company (excluding a partnership) 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 indirectly financed by the government or the central bank 7.5% 5%
Cyprus Effective January 1, 1992 10% 10% 10%
Czech Republic Effective January 1, 2012 5% where the payee is a company (excluding a partnership) 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 financed, guaranteed or insured by the government or the central bank 7.5% 10%
Denmark Effective January 1, 2013 5% where the payee is a company (excluding a partnership) 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 financed, guaranteed or insured by the government or the central bank 10% 7% for equipment royalties 10%
Ecuador Effective January 1, 2015 5% 0% when paid to the government, the central bank or a financial institution, or on a loan guaranteed or insured by the government or the central bank 10% 10%
Egypt Effective January 1, 2000 8% 0% when paid to the government or the central bank, or on a loan or credit indirectly financed by the government or the central bank 10% 8%
Estonia Effective January 1, 2000 5% where the payee is a company (excluding a partnership) 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 guaranteed by the government 10% 10%
Ethiopia Effective January 1, 2013 5% 0% when paid to the government or the central bank, or on a loan guaranteed or insured by the government or the central bank 7% 5%
Finland Effective January 1, 2011 5% where the payee is a company (excluding a partnership) 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 guaranteed or insured by the government or the central bank 10% 10%
France Effective January 1, 2015 5% where the payee is a company (excluding a partnership) 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 financed or guaranteed by a specified institution 10% 10%
Georgia Effective January 1, 2006 0% where the payee is a company holding at least 50% of the paying company's capital with a minimum investment of EUR2m or equivalent 5% where the payee is a company holding at least 10% of the paying company's capital with a minimum investment of EUR100,000 or equivalent 10% 0% when paid to the government or the central bank 10% 5%
Germany Effective January 1, 1985 New treaty signed March 28, 2014 10% When new treaty is effective: 5% where the payee is a company (excluding a partnership) 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 financed or guaranteed by a specified institution 10% When new treaty is effective: 0% when paid to the government, the central bank or a specified institution, or on a loan guaranteed or insured by the government, or on sales on credit of commercial or scientific equipment 10% 10% When new treaty is effective: 6% for equipment royalties 10% New treaty not yet in force.
Greece Effective January 1, 2006 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 10% 0% when paid to the government or the central bank 10% 10%
Hong Kong Effective January 1, 2007 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 7% 7%
Hungary Effective January 1, 1995 10% 0% when paid to the government or the central bank, or on a loan or credit indirectly financed by the government or the central bank 10% 10%
Iceland Effective January 1, 1998 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 10% 0% when paid to the government or the central bank 10% 10%
India Effective January 1, 1995 10% 0% when paid to the government or the central bank, or on a loan or credit indirectly financed by the government or the central bank 10% 10%
Indonesia Effective January 1, 2004 10% 0% when paid to the government or the central bank 10% 10%
Iran Effective January 1, 2004 10% 0% when paid to the government or the central bank 10% 10%
Ireland Effective January 1, 2001 5% where the payee is a company holding directly at least 25% of the paying company's voting stock 10% 0% when paid to the government or the central bank, or on a loan or credit indirectly financed by the government or the central bank 10% 6% for equipment royalties 10%
Israel Effective January 1, 1996 10% 7% when paid to a bank or financial institution 10% 10%
Italy Effective January 1, 1991 10% 0% when paid to the government or the central bank, or on a loan or credit indirectly financed by the government or the central bank 10% 10%
Jamaica Effective January 1, 1998 5% 0% when paid to the government or the central bank, or on a loan or credit financed, guaranteed or insured by the government or the central bank 7.5% 10%
Japan Effective January 1, 1985 10% 0% when paid to the government or the central bank, or on a loan or credit indirectly financed by the government or the central bank 10% 10%
Kazakhstan Effective January 1, 2004 10% 0% when paid to the government or the central bank, or on a loan or credit indirectly financed by the government or the central bank 10% 10%
Korea, South Effective January 1, 1995 5% where the payee is a company (excluding a partnership) 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 or indirectly financed by the government or the central bank 10% 10%
Kuwait Effective January 1, 1989 0% where the payee is the government or a company at least 20% owned by the government 5% 0% when paid to the government, the central bank or a company at least 20% owned by the government, or on a loan or credit indirectly financed by the government or the central bank 5% 10%
Kyrgyzstan Effective January 1, 2004 10% 0% when paid to the government or the central bank 10% 10%
Laos Effective January 1, 2000 5% 0% when paid to the government or the central bank 10% 10%
Latvia Effective January 1, 1998 Protocol effective January 1, 2013 5% where the payee is a company (excluding a partnership) 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 guaranteed or insured by the government or the central bank 10% 7%
Lithuania Effective January 1, 1997 5% where the payee is a company (excluding a partnership) 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 guaranteed by the government 10% 10%
Luxembourg Effective January 1, 1996 5% where the payee is a company (excluding a partnership) 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, insured or indirectly financed by the government or the central bank 10% 6% for equipment royalties 10%
Macau Effective January 1, 2004 Protocol effective January 1, 2011 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 10% 0% when paid to the government, or on a loan or credit indirectly financed by the government 7% 7%
Macedonia Effective January 1, 1998 5% 0% when paid to the government or the central bank, or on a loan or credit indirectly financed by the government or the central bank 10% 10%
Malaysia Effective January 1, 1987 10% 0% when paid to the government or the central bank 10% 10% 15% for artistic or literary copyrights or broadcasting royalties
Malta Effective January 1, 2012 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 10% 0% when paid to the government 10% 7% for equipment royalties 10%
Mauritius Effective January 1, 1996 5% 0% when paid to the government or the central bank, or on a loan or credit indirectly financed by the government or the central bank 10% 10%
Mexico Effective January 1, 2007 5% 0% when paid to the government or the central bank, or on a loan or credit guaranteed or insured by the government or the central bank 10% 10%
Moldova Effective January 1, 2002 5% where the payee is a company (excluding a partnership) 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 indirectly financed by the government or the central bank 10% 10%
Mongolia Effective January 1, 1993 5% 0% when paid to the government or the central bank, or on a loan or credit indirectly financed by the government or the central bank 10% 10%
Morocco Effective January 1, 2007 10% 0% when paid to the government or the central bank 10% 10%
Nepal Effective January 1, 2011 10% 0% when paid to the government or the central bank, or on a loan or credit indirectly financed by the government or the central bank 10% 15%
Netherlands Effective January 1, 2015 0% when paid to the government 5% where the payee is a company (excluding a partnership) 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 guaranteed or insured by the government or the central bank 10% 6% for equipment royalties 10%
New Zealand Effective January 1, 1987 10% (1) 0% when paid to the government or the central bank, or on a loan or credit financed, guaranteed or insured by the government or the central bank 10% 10%
Nigeria Effective January 1, 2010 7.50% 0% when paid to the government or the central bank 7.5% 7.50%
Norway Effective January 1, 1987 10% (1) 0% when paid to the government or the central bank, or on a loan or credit indirectly financed by the government or the central bank, or on a loan or credit guaranteed by the government 10% 10%
Oman Effective January 1, 2003 5% 0% when paid to the government or the central bank 10% 10%
Pakistan Effective July 1, 1990 10% 0% when paid to the government or the central bank 10% 10% (1)
Papua New Guinea Effective January 1, 1996 10% (1) 0% when paid to the government or the central bank 10% 10%
Philippines Effective January 1, 2002 10% (1) 0% when paid to the government or the central bank, or on a loan or credit indirectly financed by the government or the central bank 10% 10% (1)
Poland Effective January 1, 1990 10% 0% when paid to the government or the central bank, or on a loan or credit indirectly financed by the government or the central bank 10% 7% for equipment royalties 10%
Portugal Effective January 1, 2001 10% 0% when paid to the government or the central bank 10% 10%
Qatar Effective January 1, 2009 10% 0% when paid to the government or the central bank, or on a loan or credit indirectly financed by the government or the central bank 10% 10%
Romania Effective January 1, 1993 10% 0% when paid to the government or the central bank, or on a loan or credit guaranteed or indirectly financed by the government or the central bank 10% 7%
Russia Effective January 1, 1998 New treaty signed October 13, 2014 10% When new treaty is effective: 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital with a minimum investment of EUR80,000 or equivalent 10% 0% when paid to the government or the central bank 10% When new treaty is effective: 0% when paid to the government or the central bank, or on a loan guaranteed or insured by the government or the central bank 5% 10% When new treaty is effective: 6% New treaty not yet in force.
Saudi Arabia Effective January 1, 2007 0% when paid to the government 5% 0% when paid to the government or the central bank, or on a loan or credit indirectly financed by the government or the central bank 10% 10%
Montenegro Effective January 1, 1998 5% 0% when paid to the government or the central bank 10% 10%
Seychelles Effective January 1, 2000 5% 0% when paid to the government or the central bank, or on a loan or credit indirectly financed by the government or the central bank 10% 10%
Singapore Effective January 1, 2008 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 10% 0% when paid to the government or the central bank 7% when paid to a bank or financial institution 10% 6% for equipment royalties 10%
Slovenia Effective January 1, 1996 5% 10% 10%
South Africa Effective January 1, 2001 5% 0% when paid to the government or the central bank, or on a loan or credit indirectly financed by the government or the central bank 10% 7% for equipment royalties 10%
Spain Effective January 1, 1993 10% 10% 10%
Sri Lanka Effective January 1, 2006 10% 0% when paid to the government or the central bank, or on a loan or credit indirectly financed by the government or the central bank 10% 10%
Sudan Effective January 1, 2000 5% 0% when paid to the government or the central bank, or on a loan or credit indirectly financed by the government or the central bank 10% 10%
Sweden Effective January 1, 1987 Protocol effective January 1, 1997 5% where the payee is a company (excluding a partnership) 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 financed or guaranteed by a specified institution 10% 10%
Switzerland Effective January 1, 1990 New treaty signed September 25, 2013 10%When new treaty is effective: 0% when paid to the government 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 10% 0% when paid on a loan or credit guaranteed, insured or indirectly financed by the government 10% When new treaty is effective: 0% when paid to the government or the central bank, or on a loan or credit financed, guaranteed or insured by the government or the central bank 10% 10%When new treaty is effective: 9% New treaty not yet in force.
Syria Effective January 1, 2012 5% where the payee is a company (excluding a partnership) 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 guaranteed or insured by the government or the central bank 10% 10%
Tajikistan Effective January 1, 2010 5% where the payee is a company (excluding a partnership) 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 guaranteed or insured by the government or the central bank 8% 8%
Thailand Effective January 1, 1987 10% (1) 0% when paid to the government or the central bank 10% 10% (1)
Trinidad and Tobago Effective July 1, 2005 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 the central bank 10% 10%
Tunisia Effective January 1, 2004 8% 0% when paid to the government or the central bank, or on a loan or credit indirectly financed by the government or the central bank 10% 5% 10% for broadcasting royalties or the use of any copyright, patent, trademark, design or model, plan, secret formula or process, or information concerning industrial, commercial or scientific experience
Turkey Effective January 1, 1997 10% 0% when paid to the government or the central bank 10% 10%
Turkmenistan Effective January 1, 2011 5% where the payee is a company (excluding a partnership) 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 guaranteed or insured by the government or the central bank 10% 10%
Uganda Signed January 11, 2012 7.50% 0% when paid to the government or the central bank, or on a loan or credit guaranteed, insured or indirectly financed by the government or the central bank 10% 10% Not yet in force. Default rates apply.
Ukraine Effective January 1, 1997 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 10% 0% when paid to the government or the central bank 10% 10%
United Arab Emirates Effective January 1, 1995 0% where the payee is the government or a company at least 20% owned by the government 7% 0% when paid to the government, the central bank or a company at least 20% owned by the government, or on a loan or credit indirectly financed by the government or the central bank 7% 10%
United Kingdom Effective January 1, 2014 0% when paid to the government 5% where the payee is a company holding directly at least 25% of the paying company's capital 10% (1) 0% when paid to the government or the central bank, or on a loan or credit financed, guaranteed or insured by the government or the central bank 10% 6% for equipment royalties 10%
United States Effective January 1, 1987 10% 0% when paid to the government or the central bank, or on a loan or credit indirectly financed by the government or the central bank 10% 10%
Uzbekistan Effective January 1, 1997 10% 0% when paid to the government or the central bank 10% 10%
Venezuela Effective January 1, 2005 5% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital 10% 0% when paid to the government or the central bank 5% when paid to a bank 10% 10%
Vietnam Effective January 1, 1997 10% 0% when paid to the government or the central bank 10% 10%
Zambia Effective January 1, 2012 5% 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% 5%
Serbia Effective January 1, 1998 5% 0% when paid to the government or the central bank 10% 10%

Footnotes

  1. The treaty specifies a different rate but the default rate is lower and would therefore apply.
  2. PLEASE NOTE: This table was last updated February 2015

 

 

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