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New Zealand: Double Tax Treaties

Table of Treaty Rates

Provided by TreatyPro
New Zealand


Jurisdiction Status Dividends Interest Royalties Notes
           
Defaults 0/15/30% (1) 15% (2) 15%
           
Australia Effective May 1, 2010 0% where the payee is a company holding at least 80% of the paying company's voting stock for 12 months before the dividend is declared, or where the payee is the government holding directly 10% or less of the paying company's voting stock 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, the central bank or an independent financial institution (excluding bank-to-back loans) 10% 5%
Austria Effective March 1, 2008 15% 0% when paid to the government, or on a loan or credit financed, guaranteed or insured by a specified institution 10% 10%
Belgium Effective April 1, 1984 15% 10% 10%
Canada Effective April 1, 1976 New treaty signed May 3, 2012 15% When new treaty is effective: 5% where the payee is a company holding directly at least 10% of the paying company's voting stock 15% 15% When new treaty is effective: 0% when paid on a loan or credit financed, guaranteed or insured by a specified institution 10% 15% When new treaty is effective: 5% 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% New treaty not yet in force.
Chile Effective January 1, 2007 15% 10% when paid on a bank or insurance company loan 15% 5% (3)
China Effective April 1, 1987 15% 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%
Czech Republic Effective January 1, 2009 15% 0% when paid to the government or the central bank, or on a loan or credit financed, guaranteed or insured by a specified institution 10% 10%
Denmark Effective April 1, 1981 15% 10% 10%
Fiji Effective April 1, 1976 Protocol effective April 1, 1987 15% 0% when paid to the central bank 10% 15%
Finland Effective April 1, 1985 15% 10% 10%
France Effective April 1, 1982 15% 0% when paid to the government, or on a loan or credit financed or guaranteed by the government 10% 10%
Germany Effective April 1, 1978 15% 0% when paid to the government, the central bank or a specified institution 10% 10%
Hong Kong Effective April 1, 2012 0% where the payee is a company holding at least 50% of the paying company's voting stock, the government or the central bank 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, the central bank or an independent financial institution (excluding bank-to-back loans) 10% 5%
India Effective April 1, 1987 Protocol effective April 1, 2000 15% 0% when paid to the government, the central bank or a specified institution 10% 10%
Indonesia Effective April 1, 1989 15% 0% when paid to the government or the central bank 10% 15%
Ireland Effective April 1, 1989 15% 10% 10%
Italy Effective April 1, 1978 15% 0% when paid to or by the government, or on a loan approved by both governments 10% 10%
Japan Effective January 1, 2014 0% where the payee is a company holding at least 10% of the paying company's voting stock for six months before the dividend is declared 15% 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% 5%
Korea, South Effective April 1, 1981 15% 0% when paid to the government or the central bank, or on a loan or credit financed by a specified institution 10% 10%
Malaysia Effective April 1, 1974 15% 15% 15%
Mexico Effective August 1, 2007 0% where the payee is a company holding at least 80% of the paying company's voting stock for 12 months before the dividend is declared 5% where the payee is a company holding directly at least 10% of the paying company's voting stock 15% (5) 0% when paid to or by the government or the central bank, or on a loan or credit financed. guaranteed or insured for at least three years by a specified institution 10% 10%
Netherlands Effective April 1, 1979 15% 0% when paid to the government or the central bank 10% 10%
Norway Effective April 1, 1982 15% 0% when paid to or by the government, or on a loan approved by both governments 10% 10%
Papua New Guinea Effective March 1, 2014 15% 0% when paid to the government or the central bank 10% 10%
Philippines Effective April 1, 1981 Protocol effective December 1, 2008 15% 0% when paid to the government or the central bank 10% 15%
Poland Effective April 1, 2007 15% 10% 10%
Russia Effective January 1, 2004 15% 10% 10%
Singapore Effective October 1, 2010 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 the central bank 10% 5%
South Africa Effective September 1, 2004 15% 0% when paid to the government or the central bank 10% 10%
Spain Effective September 1, 2006 15% 0% when paid to the government 10% 10%
Sweden Effective April 1, 1981 15% 10% 10%
Switzerland Effective April 1, 1981 15% 10% 10%
Taiwan Effective February 1, 1998 15% 10% 10%
Thailand Effective January 1, 1999 15% 0% when paid to the government, the central bank or a specified institution 10% when paid to a financial institution or insurance company, or on sales on credit of equipment, merchandise or services 15% 10% for copyright, broadcasting or equipment royalties 15%
Turkey 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 15% 0% when paid to the government or the central bank 10% when paid to a bank 15% 10%
United Arab Emirates Effective September 1, 2004 15% 0% when paid to the government or the central bank 10% 10%
United Kingdom Effective April 1, 1985 Protocol effective April 1, 2005 15% 0% when paid to the government, or on a loan or credit financed, guaranteed or insured by a specified institution 10% 10%
United States Effective April 1, 1984 Protocol effective January 1, 2011 0% where the payee is a company holding at least 80% of the paying company's voting stock for 12 months before the dividend is declared 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, a bank or financial institution, or on a loan or credit guaranteed or insured by the government 10% 5% Separate dividend withholding tax rules apply to REITs.
Vietnam Effective January 1, 2015 5% where the payee is a company holding directly at least 50% of the paying company's voting stock 15% 10% 10%

Footnotes

  1. "The withholding tax rate imposed on dividends in New Zealand varies according to whether they are fully imputed (ie the company making the dividend payment has paid tax already on the income); if the payee is a company holding at least 10% of the paying company's voting stock the rate is 0%. Dividends not fully imputed are subject to a 30% rate.
  2. "A 0% rate can be imposed under the Approved Issuer Levy scheme, to interest payments made to non-resident lenders by 'approved issuers'. A 2% approved issuer levy is payable instead in such instances.
  3. Under its Most Favoured Nation (MFN) obligations to Chile, New Zealand announced on 12 August 2011 that, retroactively from 1 May 2010, the withholding tax rate on royalties would be reduced from 10% to 5%.
  4. The domestic rate applies.
  5. Under its Most Favoured Nation (MFN) obligations to Mexico, New Zealand announced on 12 August 2011 that, retroactively from 1 May 2010, with withholding tax rate on dividends would be reduced to 0% where the company receiving the dividend has held 80% of the voting power in the company making the payment, for at least 12 months prior to the distribution date, and to 5% where the payee holds directly at least 10% of the paying company's voting stock. The rate remains 15% in all other cases.
  6. PLEASE NOTE: This table was last updated February 2015

 

 

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