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Canada: Double Tax Treaties

Table of Treaty Rates

Provided by TreatyPro
Canada


Jurisdiction Status Dividends Interest Royalties Notes
           
Defaults 25% 0/25% (1) 0% for copyright royalties (excluding broadcasting royalties) 25%
           
Algeria Effective January 1, 2001 15% 0% when paid to or by the government, or on a loan approved by both governments 15% 0% for the use of any computer software or patent (excluding a rental or franchise agreement) 15%
Argentina Effective January 1, 1995 10% where the payee is a company holding directly at least 25% 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, or on sales on credit of equipment or machinery 12.5% 3% for news royalties 5% for literary, artistic, dramatic or musical copyright royalties (excluding broadcasting royalties) 10% for the use of any patent, trademark, design or model, plan, secret formula or process, or industrial or scientific experience information or equipment 15%
Armenia Effective January 1, 2006 5% where the payee is a company holding directly at least 25% of the paying company's capital with a minimum investment of USD100,000 or equivalent 15% 0% when paid to the government, or on a loan or credit financed, guaranteed or insured by a government approved institution 10% 10%
Australia Effective January 1, 1976 Protocol effective January 1, 2003 5% where the payee is a company holding at least 10% of the paying company's voting stock 15% (2) 10% 10%
Austria Effective January 1, 1981 Protocol effective March 1, 2001 5% where the payee is a company holding at least 10% of the paying company's voting stock 15% (2) 0% when paid to the government, the central bank or a pension fund, or on government bonds or debentures, or on a loan or credit financed, guaranteed or insured by a specified institution, or on sales on credit of equipment or merchandise 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%
Azerbaijan Effective January 1, 2007 10% where the payee is a company holding at least 10% of the paying company's voting stock 15% 0% when paid to or by the government or the central bank 10% 5% for the use of any computer software, patent or information concerning industrial, commercial or scientific experience (excluding a rental or franchise agreement) 10%
Bangladesh Effective January 1, 1982 15% 0% when paid on government bonds or debentures, or on a loan or credit financed, guaranteed or insured by a government approved institution 15% 10%
Barbados Effective January 1, 1976 15% 0% when paid on government bonds or debentures 15% 0% for literary, artistic, dramatic or musical copyright royalties (excluding broadcasting royalties) 10%
Belgium 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 government approved 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%
Brazil Effective January 1, 1986 15% where the payee is a company holding at least 10% of the paying company's capital 25% (3) 0% when paid to the government 15% 15% 25% for trademark royalties
Bulgaria Effective January 1, 2002 10% where the payee is a company holding at least 10% of the paying company's voting stock 15% (2) 0% when paid to the government or the central bank, or on government bonds, or on a loan financed, guaranteed or insured by the central bank or a specified institution 10% 0% for cultural, artistic, dramatic or musical copyright royalties (excluding broadcasting royalties) 10%
Cameroon Effective January 1, 1998 15% 15% 15%
Chile Effective January 1, 2000 10% where the payee is a company holding at least 25% of the paying company's voting stock 15% 15% 15%
China Effective January 1, 1987 10% where the payee is a company holding at least 10% of the paying company's voting stock 15% 0% when paid to the government or the central bank, or on a loan financed or guaranteed by the central bank or a specified institution 10% 10%
Colombia Effective January 1, 2013 5% where the payee is a company holding at least 10% of the paying company's voting stock 15% 10% 10%
Cote d'Ivoire Effective January 1, 1986 15% 0% when paid to the government 15% 10%
Croatia Effective January 1, 2000 5% where the payee is a company holding at least 10% of the paying company's voting stock or holding directly at least 25% of the paying company's capital 15% (2) 10% 10%
Cyprus Effective January 1, 1985 15% 0% when paid on government bonds or debentures, or on a loan or credit financed, guaranteed or insured by a specified institution 15% 0% for literary, artistic, dramatic or musical copyright royalties (excluding broadcasting royalties) 10%
Czech Republic Effective January 1, 2003 5% where the payee is a company holding at least 10% of the paying company's voting stock 15% (2) 0% when paid to the government or a pension fund, or on a loan or credit financed, guaranteed or insured by a government institution in respect of imports or exports, or on sales on credit of equipment, merchandise or services 10% 10%
Denmark Effective January 1, 1999 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 10% where the payer is a non-resident owned investment corporation and the payee is a company holding at least 25% of its capital 15% 0% when paid to the government or a pension fund, or between the central banks, or on a loan or credit financed, guaranteed or insured by a specified institution, or on sales on credit of equipment, merchandise or services, or as a penalty charge for late payments 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%
Dominican Republic Effective January 1, 1997 18% 0% when paid on government bonds or debentures, or on a loan or credit financed, guaranteed or insured by a government approved institution 18% 0% for literary, artistic, dramatic or musical copyright royalties (excluding broadcasting royalties) 18%
Ecuador Effective January 1, 2002 5% where the payee is a company holding at least 25% of the paying company's voting stock 15% (2) 0% when paid to the government or the central bank, or on a loan or credit financed, guaranteed or insured by a government approved institution 15% 10% for equipment royalties 15%
Egypt Effective January 1, 1985 15% 0% when paid to the government, or on a loan financed, guaranteed or insured by the government 15% 15%
Estonia Effective January 1, 1996 5% where the payee is a company holding directly at least 25% of the paying company's voting stock 15% (2) 0% when paid to the government or the central bank, or on a loan guaranteed or insured by the government or the central bank, or on sales on credit of merchandise or equipment, or as a penalty charge for late payments 10% 10%
Finland Effective January 1, 2007 5% where the payee is a company holding at least 10% of the paying company's voting stock 15% 0% when paid to the government, or between the central banks, or on a loan or credit financed, guaranteed or insured by a specified institution, or on sales on credit of equipment or merchandise, or as a penalty charge for late payments 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), or when paid to the government 10%
France Effective January 1, 1976 Protocol effective September 1, 1998 5% where the payee is a company holding at least 10% of the paying company's voting stock 10% where the payer is a non-resident owned investment corporation and the payee is a company holding at least 10% of its voting stock 15% 0% when paid between the central banks, or on government bonds or debentures, or on a loan financed or guaranteed by an institution in respect of external trade, or on sales on credit of equipment, merchandise or services, or as a penalty charge for late payments 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), or when paid to the government 10%
Gabon Effective January 1, 2009 15% 0% when paid to the government 10% 10%
Germany Effective January 1, 2001 5% where the payee is a company holding at least 10% of the paying company's voting stock 15% 0% when paid by the government, or to the government, the central bank, a pension fund or a specified institution, or on sales on credit of equipment or merchandise 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%
Greece Effective January 1, 2011 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, or on a loan or credit financed, guaranteed or insured by a specified institution 10% 0% for cultural or artistic copyright royalties (excluding broadcasting royalties) 10%
Guyana Effective January 1, 1987 15% 0% when paid to the government 15% 10%
Hong Kong Effective January 1, 2014 5% where the payee is a company (excluding a partnership) holding at least 10% of the paying company's voting stock 15% 0% when paid to the government or the central bank, or when the payee is dealing at arm's length with the payer 10% 10%
Hungary Effective January 1, 1995 Protocol effective January 1, 1997 5% where the payee is a company holding at least 25% of the paying company's voting stock 10% where the payer is a non-resident owned investment corporation and the payee is a company holding at least 25% of its voting stock 15% 0% when paid to a pension fund, or on government bonds or debentures, or on a loan or credit financed, guaranteed or insured by the central bank or a government approved institution 10% 0% for cultural, artistic, dramatic or musical copyright royalties (excluding broadcasting royalties) 10%
Iceland Effective January 1, 1999 5% where the payee is a company holding at least 10% of the paying company's voting stock 15% (2) 0% when paid by the government, or to a pension fund, or on a loan or credit financed, guaranteed or insured by the central bank or a government approved institution 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%
India Effective January 1, 1998 15% where the payee is a company holding at least 10% of the paying company's voting stock 25% 0% when paid by the government, or to the central bank or a government approved institution, or on a loan or credit financed, guaranteed or insured by a specified institution 15% 10% for equipment royalties 15%
Indonesia Effective January 1, 1980 Protocol effective January 1, 1999 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 on a loan or credit financed by a government approved institution 10% 10%
Ireland Effective January 1, 2006 5% where the payee is a company holding at least 10% of the paying company's voting stock 15% (2) 0% when paid by the government, or to a pension fund, or on a loan or credit financed, guaranteed or insured in respect of a government export credit guarantee scheme, 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%
Israel Effective April 1, 1976 15% 0% when paid on a loan financed by a government approved institution 15% 0% for literary, artistic, dramatic or musical copyright royalties (excluding broadcasting royalties) 15%
Italy Effective January 1, 2011 5% where the payee is a company holding at least 10% of the paying company's voting stock 15% (2) 0% when paid to or by the government, or on a loan or credit financed, guaranteed or insured by a government approved institution 10% 0% for literary, artistic, dramatic or musical copyright royalties (excluding broadcasting royalties) 5% for the use of any computer software or patent, or information concerning industrial, commercial or scientific experience (excluding a rental or franchise agreement) 10%
Jamaica Effective January 1, 1997 15% 15% 10%
Japan Effective January 1, 1988 Protocol effective January 1, 2001 5% where the payee is a company holding at least 25% of the paying company's voting stock for six months before the end of the distribution's accounting period 15% 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%
Jordan Effective January 1, 2001 10% where the payee is a company holding at least 10% of the paying company's voting stock 15% (2) 0% when paid to the government, or on a loan financed, guaranteed or insured by the government 10% 10%
Kazakhstan Effective January 1, 1996 5% where the payee is a company holding at least 10% of the paying company's voting stock 15% (2) 0% when paid by the government, or on a loan or credit financed, guaranteed or insured by a specified institution 10% 10%
Kenya Effective January 1, 1987 15% where the payee is a company holding at least 10% of the paying company's voting stock for six months before payment of the dividend 25% 0% when paid to the government or the central bank 15% 15%
Korea, South Effective January 1, 2007 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's voting stock 15% 0% when paid to the government or the central bank, or on a loan or credit guaranteed or insured by a government institution in respect of imports or exports, or on sales on credit of equipment or merchandise 10% 10%
Kuwait Effective January 1, 2003 5% where the payee is a company holding at least 10% of the paying company's voting stock or at least 25% of its capital 15% (2) 0% when paid by the government, or on a loan or credit financed, guaranteed or insured by the government or a government approved institution in respect of exports 10% 10%
Kyrgyzstan Effective February 1, 2001 15% 0% when paid by the government, or on a loan or credit financed, guaranteed or insured by a government approved institution 15% 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%
Latvia Effective January 1, 1996 5% where the payee is a company holding directly at least 25% of the paying company's voting stock 15% (2) 0% when paid to or on a loan guaranteed or insured by the government, the central bank or a government approved institution, or on sales on credit of merchandise or equipment, or as a penalty charge for late payments 10% 10%
Lebanon Signed December 29, 1998 5% where the payee is a company holding at least 10% of the paying company's voting stock 15% (2) 0% when paid by the government 10% 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% Not yet in force. Default rates apply.
Lithuania Effective January 1, 1998 5% where the payee is a company holding directly at least 25% of the paying company's voting stock 15% (2) 0% when paid to or on a loan guaranteed or insured by the government, the central bank or a government approved institution, or on sales on credit of merchandise or equipment, or as a penalty charge for late payments 10% 10%
Luxembourg Effective January 1, 2001 0% when paid to a pension fund 5% where the payee is a company (excluding a partnership) holding at least 10% of the paying company's voting stock 10% where the payer is a non-resident owned investment corporation and the payee is a company (excluding a partnership) holding at least 25% of its capital 15% 0% when paid by the government, or to a pension fund, or on sales on credit of equipment or merchandise, or as a penalty charge for late payments 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%
Malaysia Effective January 1, 1980 15% 15% 15%
Malta Effective January 1, 1987 15% 0% when paid to the government, the central bank or a specified institution 15% 0% for literary, artistic, educational, dramatic or musical copyright royalties (excluding broadcasting royalties) 10%
Mexico Effective January 1, 2008 5% where the payee is a company holding at least 10% of the paying company's voting stock 15% 0% when paid to or by the government or the central bank, or to a pension fund, or on a loan or credit financed, guaranteed or insured for at least three years by a specified institution 10% 0% for cultural, artistic, dramatic or musical copyright royalties (excluding broadcasting royalties) 10%
Moldova Effective January 1, 2003 5% where the payee is a company holding at least 25% of the paying company's voting stock 15% 0% when paid by the government, or to a pension fund 10% 10%
Mongolia Effective January 1, 2003 5% where the payee is a company holding at least 10% of the paying company's voting stock 15% (2) 0% when paid by the government, or on a loan or credit financed, guaranteed or insured by a government institution in respect of imports or exports 10% 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%
Morocco Effective January 1, 1978 15% 0% when paid on government bonds or debentures 15% 5% for literary, artistic, dramatic or musical copyright royalties (excluding broadcasting royalties) 10%
Namibia Signed March 25, 2010 5% where the payee is a company (excluding a partnership) holding at least 25% of the paying company's voting stock 15% 0% when paid to or by the government, or to a pension fund, or on a loan or credit financed guaranteed or insured by a government approved institution in respect of exports 10% 0% for literary, artistic, dramatic or musical copyright royalties (excluding broadcasting royalties) 10% Not yet in force. Default rates apply.
Netherlands Effective January 1, 1987 Protocol effective January 15, 1999 5% where the payee is a company (excluding a partnership) holding at least 10% of the paying company's voting stock or at least 25% of its capital 10% where the payer is a non-resident owned investment corporation and the payee is a company (excluding a partnership) holding at least 10% of the paying company's voting stock or at least 25% of its capital 15% 0% when paid to the government or the central bank, or on government bonds or debentures, or on a loan or credit financed, guaranteed or insured by a government approved institution, or on sales on credit of equipment or merchandise 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%
New Zealand Effective January 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 to an independent financial institution (excluding bank-to-back loans), or on a loan or credit financed, guaranteed or insured by a government approved 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.
Nigeria Effective January 1, 2000 12.5% where the payee is a company holding at least 10% of the paying company's voting stock 15% 0% when paid to the government 12.5% 12.50%
Norway Effective January 1, 2003 5% where the payee is a company holding directly at least 10% of the paying company's voting stock 15% (2) 0% when paid on government bonds or debentures, or to or on a loan financed, guaranteed or insured by a specified institution 10% 0% for the use of any cultural, 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%
Oman Effective January 1, 2006 5% where the payee is a company holding at least 10% of the paying company's voting stock 15% 0% when paid to the government or a pension fund, or on a loan or credit financed, guaranteed or insured by a specified institution 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%
Pakistan Effective January 1, 1977 15% 0% when paid to the central bank, or on government bonds or debentures, or on a loan financed by a government institution 15% 0% for literary, artistic, dramatic or musical copyright royalties (excluding broadcasting royalties) 15%
Papua New Guinea Effective January 1, 1990 15% 0% when paid on a loan financed, guaranteed or insured by a government approved institution 10% 10%
Peru Effective January 1, 2004 10% where the payee is a company holding at least 10% of the paying company's voting stock 15% 15% 15%
Philippines Effective January 1, 1977 15% 0% when paid on government bonds or debentures, or on a loan or credit financed, guaranteed or insured by a government approved institution 15% 10%
Poland Effective January 1, 2014 15% When new treaty is effective: 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 financed, guaranteed or insured by the government or a government approved institution 15% When new treaty is effective: 0% when paid on a loan or credit financed, guaranteed or insured by a government institution in respect of exports, or on sales on credit of equipment, merchandise or services 10% 0% for literary, artistic, dramatic or musical copyright royalties (excluding broadcasting royalties) 10% When new treaty is effective: 0% for the use of any literary, artistic, dramatic or musical copyright (excluding broadcasting royalties), patent, or information concerning industrial, commercial or scientific experience (excluding a rental or franchise agreement) 10%
Portugal Effective January 1, 2002 10% where the payee is a company holding at least 25% of the paying company's voting stock 15% (2) 0% when paid to or by the government, or on a loan or credit financed by a specified institution 10% 10%
Romania Effective January 1, 2005 5% where the payee is a company holding at least 10% of the paying company's voting stock 15% (2) 0% when paid by the government, or on a loan or credit financed, guaranteed or insured by a specified institution 10% 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%
Russia Effective January 1, 1998 10% where the payee is a company holding at least 10% of the paying company's voting stock 15% 0% when paid by the government, or to the central bank, or on a loan or credit financed, guaranteed or insured by a government approved institution 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%
Senegal Effective January 1, 2004 15% 0% when paid by the government, or on a loan or credit financed, guaranteed or insured by a government approved institution 15% 15%
Singapore Effective January 1, 1977 15% 15% 15%
Slovakia Effective January 1, 2002 5% where the payee is a company holding at least 10% of the paying company's voting stock 15% (2) 0% when paid by the government, or on a loan or credit financed, guaranteed or insured by a government institution in respect of imports or exports 10% 0% for literary, artistic, dramatic or musical copyright royalties (excluding broadcasting royalties) 10%
Slovenia Effective January 1, 2003 5% where the payee is a company holding at least 10% of the paying company's voting stock 15% (2) 0% when paid by the government, or to a pension fund, or on a loan or credit financed, guaranteed or insured by a specified institution 10% 10%
South Africa Effective July 1, 1997 5% where the payee is a company holding at least 10% of the paying company's voting stock 15% (2) 0% when paid by the government, or to the central bank or a pension fund, or on sales on credit of equipment, merchandise or services 10% 6% 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%
Spain Effective January 1, 1980 15% 0% when paid on a loan or credit financed, guaranteed or insured by a specified institution 15% 0% for literary, artistic, dramatic or musical copyright royalties (excluding broadcasting royalties) 10%
Sri Lanka Effective January 1, 1986 15% 0% when paid on government bonds, securities or debentures, or on a loan or credit guaranteed or insured by a specified institution 15% 0% for literary, artistic, dramatic or musical copyright royalties (excluding broadcasting royalties) 10%
Sweden Effective January 1, 1998 0% when paid to a pension fund 5% where the payee is a company holding directly at least 10% of the paying company's voting stock or at least 25% of its capital 10% where the payer is a non-resident owned investment corporation and the payee is a company holding directly at least 10% of the paying company's voting stock or at least 25% of its capital 15% 0% when paid by the government or the central bank, or to a pension fund, or on a loan or credit financed, guaranteed or insured by a specified institution, or on sales on credit of equipment, merchandise or services, or as a penalty charge for late payments 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%
Switzerland Effective January 1, 1998 Protocol effective January 1, 2012 0% when paid to the central bank or a pension fund 5% where the payee is a company holding at least 10% of the paying company's voting stock and capital 15% 0% when paid on a loan or credit financed, guaranteed or insured by a specified institution 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%
Tanzania Effective January 1, 1998 20% where the payee is a company holding at least 15% of the paying company's voting stock 25% 0% when paid to a pension fund, or on government bonds or debentures, or on a loan or credit financed, guaranteed or insured by a government institution 15% 20%
Thailand Effective January 1, 1985 15% 0% when paid to the government or the central bank 15% 5% for literary, artistic, dramatic or musical copyright royalties (excluding broadcasting royalties) 15%
Trinidad and Tobago Effective April 1, 1996 5% where the payee is a company holding at least 10% of the paying company's voting stock 15% (2) 0% when paid by the government, or to a pension fund, or on a loan or credit financed by a government institution 10% 0% for literary, artistic, dramatic or musical copyright royalties (excluding broadcasting royalties) 10%
Tunisia Effective January 1, 1985 15% 0% when paid on a loan or credit financed, guaranteed or insured by a government approved institution 15% 0% for literary, artistic, dramatic or musical copyright royalties (excluding broadcasting royalties) 15% 20% for broadcasting royalties, or the use of any patent, trademark or equipment
Turkey Effective January 1, 2012 15% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's voting stock 20% 0% when paid to the government or the central bank 15% 10%
Ukraine Effective October 21, 1996 5% where the payee is a company holding at least 20% of the paying company's voting stock 15% 0% when paid by the government, or to a pension fund, or on a loan or credit financed, guaranteed or insured by a government institution in respect of imports or exports 10% 0% for the use of computer software 10%
United Arab Emirates Effective January 1, 2004 5% where the payee is a company holding at least 10% of the paying company's voting stock 10% where the payer is a non-resident owned investment corporation and the payee is a company holding at least 10% of its voting stock 15% 0% when paid to the government or the central bank 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%
United Kingdom Effective January 1, 1976 Protocol effective January 1, 2005 5% where the payee is a company holding at least 10% of the paying company's voting stock 15% 0% when paid on government bonds or debentures, 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%
United States Effective October 1, 1984 Protocol effective February 1, 2009 5% where the payee is a company holding at least 10% of the paying company's voting stock 15% 0% 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% Separate dividend withholding tax rules apply to REITs.
Uzbekistan Effective January 1, 2001 5% where the payee is a company holding at least 10% of the paying company's voting stock 15% 0% when paid by the government, or on a loan or credit financed, guaranteed or insured by the central bank 10% 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%
Venezuela Effective January 1, 2005 10% where the payee is a company holding at least 25% of the paying company's voting stock 15% (2) 0% when paid by the government, or on a loan or credit financed, guaranteed or insured by a specified institution 10% 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%
Vietnam Effective January 1, 1999 5% where the payee is a company holding at least 70% of the paying company's voting stock 10% where the payee is a company holding at least 25% of the paying company's voting stock 15% 0% when paid by the government, or on a loan or credit financed, guaranteed or insured by a government institution 10% 10%
Zambia Effective January 1, 1989 15% 15% 15%
Zimbabwe Effective January 1, 1995 10% where the payee is a company holding at least 25% of the paying company's voting stock 15% 0% when paid to a pension fund, or on government bonds or debentures 15% 10%
Serbia Effective January 1, 2014 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's voting stock 15% 0% when paid to the government or the central bank 10% 10%

Footnotes

  1. Withholding tax on certain interest payments to arm's length foreign lenders was eliminated in 2008; 'participating debt interest' (broadly defined as interest payments where any part depends on the production or use of assets in Canada, or is calculated in relation to the revenue, cash flow, profit or commodity price of a company based in Canada) remains subject to withholding tax.
  2. The highest dividend withholding tax rate also applies where the payee is a non-resident-owned investment corporation that is a resident of Canada.
  3. The domestic rate applies.
  4. PLEASE NOTE: This table was last updated February 2015

 

 

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