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Germany: Double Tax Treaties

Table Of Treaty Rates

Provided by TreatyPro
Germany


Jurisdiction Status Dividends Interest Royalties Notes
           
Defaults 25% 0% 25% when paid by German banks, or on convertible bonds 15%
           
Albania 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% 5%
Algeria Effective January 1, 2009 5% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital 15% 0% 10%
Argentina Effective January 1, 1976 15% 0% 15%
Armenia Effective January 1, 1980 15% 0% 0% The USSR treaty continues to apply.
Australia Effective July 1, 1971 15% 0% 10%
Austria Effective January 1, 2003 5% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital 15% 0% 0%
Azerbaijan Effective January 1, 2005 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% 5% 10% for broadcasting royalties or the use of any literary or artistic copyrights, patent, trademark or design
Bangladesh Effective January 1, 1990 15% 0% 10%
Belarus Effective January 1, 2007 5% where the payee is a company holding at least 20% of the paying company's capital with a value of at least EUR81,806.70 or equivalent 15% 0% 3% 5% for literary or artistic copyrights, broadcasting or equipment royalties
Belgium Effective January 1, 1966 15% 0% 0%
Bolivia Effective January 1, 1991 10% 0% 15%
Bosnia and Herzegovina Effective January 1, 1988 15% 0% 10% The Yugoslavia treaty continues to apply.
Bulgaria Effective January 1, 2012 5% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital 15% 0% 5%
Canada Effective January 1, 2001 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%
China 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% 10% When new treaty is effective: 6% for equipment royalties 10% New treaty not yet in force.
Costa Rica Signed February 13, 2014 5% where the payee is a company (excluding a partnership) holding directly at least 20% of the paying company's capital 15% 0% 10% Not yet in force. Default rates apply.
Cote d'Ivoire Effective January 1, 1982 15% 0% 10%
Croatia Effective January 1, 2007 5% where the payee is a company holding at least 10% of the paying company's capital 15% 0% 0%
Cyprus Effective January 1, 2012 5% where the payee is a company holding directly at least 10% of the paying company's capital 15% 0% 0%
Czech Republic Effective January 1, 1984 5% where the payee is a company holding directly at least 25% of the paying company's capital 15% 0% 5% The Czechoslovakia treaty continues to apply.
Denmark Effective January 1, 1997 5% where the payee is a company holding directly at least 10% of the paying company's capital 15% 0% 0%
Ecuador Effective January 1, 1987 15% 0% 15%
Egypt Effective January 1, 1992 15% 0% 15% (5)
Estonia Effective January 1, 1994 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% 5% for equipment royalties 10%
Finland Effective January 1, 1981 10% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% 0% for copyright or broadcasting royalties 5%
France Effective January 1, 1958 Protocol effective January 1, 1990 5% where the payee is a company holding at least 10% of the paying company's capital 15% 0% 0%
Georgia Effective January 1, 2007 0% where the payee is a company (excluding a partnership) holding directly at least 50% of the paying company's capital with a minimum investment of EUR3m or equivalent 5% where the payee is a company (excluding a partnership) holding at least 10% of the paying company's capital with a minimum investment of EUR100,000 or equivalent 10% 0% 0%
Ghana Effective January 1, 2008 5% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital 15% 0% 8%
Greece Effective January 1, 1964 25% 0% 0%
Hungary Effective January 1, 2012 5% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital 15% 0% 0%
Iceland Effective January 1, 1968 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% 0%
India Effective January 1, 1997 10% 0% 10%
Indonesia Effective January 1, 1992 10% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% 10% for equipment royalties, or the use of information concerning industrial, commercial or scientific experience 15%
Iran Effective January 1, 1970 15% where the payee is a company holding directly at least 25% of the paying company's capital and voting stock 20% 0% 10%
Ireland Effective January 1, 2013 5% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital 15% 0% 0%
Israel Effective January 1, 1961 Protocol effective January 1, 1970 New treaty signed August 21, 2014 25% When new treaty is effective: 5% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital 10% 0% 0% for literary, artistic, dramatic or musical copyright royalties (excluding broadcasting royalties) 5% When new treaty is effective: 0% New treaty not yet in force.
Italy Effective January 1, 1993 15% 0% 0% for literary, artistic, dramatic or musical copyrights or broadcasting royalties 5%
Jamaica Effective January 1, 1973 10% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% 10%
Japan Effective January 1, 1967 Protocol effective January 1, 1977 15% 0% 10%
Kazakhstan 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 15% 0% 10%
Kenya Effective January 1, 1980 15% 0% 15%
Korea, South Effective January 1, 2003 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% 2% for equipment royalties 10%
Kuwait Effective January 1, 1998 5% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital 15% 0% 10%
Kyrgyzstan Effective January 1, 2007 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% 10%
Latvia 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 15% 0% 5% for equipment royalties 10%
Liberia Effective January 1, 1970 10% where the payee is a company holding at least 25% of the paying company's capital 15% 0% 10% 20% for copyright or trademark royalties (excluding broadcasting royalties)
Liechtenstein Effective January 1, 2013 0% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's voting stock for 12 months before payment of the dividend 5% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's voting stock 15% 0% 0%
Lithuania 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 15% 0% 5% for equipment royalties 10%
Luxembourg Effective January 1, 2014 10% where the payee is a company holding at least 25% of the paying company's voting stock 15% When new treaty is effective: 5% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital 15% 0% 5%
Macedonia Effective January 1, 2011 5% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital 15% 0% 5%
Malaysia Effective January 1, 2011 5% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital 15% 0% 7%
Malta Effective January 1, 2002 5% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital 15% 0% 0%
Mauritius Effective January 1, 2013 5% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital 15% 0% 10%
Mexico Effective January 1, 2010 5% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital 15% 0% 10%
Moldova Effective January 1, 1980 15% 0% 0% The USSR treaty continues to apply.
Mongolia Effective January 1, 1997 5% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital 10% 0% 10%
Morocco Effective November 1, 1974 5% where the payee is a company holding directly at least 25% of the paying company's capital 15% 0% 10%
Namibia Effective January 1, 1993 10% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital 15% 0% 10%
Netherlands Effective January 1, 1956 New treaty signed April 12, 2012 10% where the payee is a company holding at least 25% of the paying company's voting stock 15% When new treaty is effective: 5% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital 10% when paid to a pension fund 15% 0% 0% New treaty not yet in force.
New Zealand Effective January 1, 1978 15% 0% 10%
Norway Effective January 1, 1991 0% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% 0%
Oman Signed August 15, 2012 5% where the payee is a company holding directly at least 10% of the paying company's capital 10% 15% where the payer is a tax exempt real estate investment company 0% 8% Not yet in force. Default rates apply.
Pakistan Effective January 1, 1995 10% where the payee is a company (excluding a partnership) holding directly at least 20% of the paying company's capital 15% 0% 10%
Papua New Guinea Signed January 17, 1995 15% 0% 10% Not yet in force. Default rates apply.
Philippines Effective January 1, 1985 New treaty signed September 9, 2013 10% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% When new treaty is effective: 5% where the payee is a company (excluding a partnership) holding directly at least 70% of the paying company's capital 10% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% 10% 15% for copyright or broadcasting royalties When new treaty is effective: 10% New treaty not yet in force.
Poland Effective January 1, 2005 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% 5%
Portugal Effective January 1, 1983 15% 0% 10%
Romania 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% 3%
Russia Effective January 1, 1997 Protocol effective January 1, 2010 5% where the payee is a company holding directly at least 10% of the paying company's capital with a value of at least EUR80,000 or equivalent 15% 0% 0%
Montenegro Effective January 1, 1988 15% 0% 10% The Yugoslavia treaty continues to apply.
Singapore Effective January 1, 2007 5% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital 15% 0% 8%
Slovakia Effective January 1, 1984 5% where the payee is a company holding directly at least 25% of the paying company's capital 15% 0% 5% The Czechoslovakia treaty continues to apply.
Slovenia Effective January 1, 2007 5% where the payee is a company holding directly at least 25% of the paying company's capital 15% 0% 5%
South Africa Effective January 1, 1965 New treaty signed September 9, 2008 7.5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's voting stock 15% When new treaty is effective: 5% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital 15% 0% 0% New treaty not yet in force.
Spain Effective January 1, 2013 5% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital 15% 0% 0%
Sri Lanka Effective January 1, 1983 15% 0% 10%
Sweden Effective January 1, 1995 0% where the payee is a company holding directly at least 10% of the paying company's capital 15% 0% 0%
Switzerland Effective January 1, 1972 Protocol effective January 1, 2012 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 5% when paid by a hydro-electric power company operating on the Rhine 15% 25% when paid from profit-sharing bonds (5) 0% 0%
Syria Effective January 1, 2011 5% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital 10% 0% 12%
Taiwan Effective January 1, 2013 10% 0% 10%
Tajikistan Effective January 1, 2005 5% where the payee is a company (excluding a partnership) holding at least 10% of the paying company's capital 15% 0% 5%
Thailand Effective January 1, 1967 15% where the payee is a company holding at least 25% of the paying company's voting stock 20% 0% 5% for copyright royalties (excluding broadcasting royalties) 15%
Trinidad and Tobago 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 20% 0% 0% for copyright royalties (excluding broadcasting royalties) 10%
Tunisia Effective January 1, 1977 10% where the payee is a company holding directly at least 25% of the paying company's capital 15% 0% 10% 15% for broadcasting royalties, or the use of any patent, trademark, design or model, plan, secret formula or process
Turkey 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 15% 0% 10%
Turkmenistan Effective January 1, 1980 15% 0% 0% The USSR treaty continues to apply.
Ukraine Effective January 1, 1997 5% where the payee is a company (excluding a partnership) holding directly at least 20% of the paying company's capital 10% 0% 0% 5% for literary or artistic copyrights or broadcasting royalties
United Arab Emirates Effective January 1, 2009 5% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital 10% 15% where the payer is a tax exempt real estate investment company 0% 10%
United Kingdom Effective January 1, 2011 5% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital 10% when paid to a pension fund 15% 0% 0%
United States Effective January 1, 1990 Protocol effective January 1, 2007 0% where the payee is a company holding directly at least 80% of the paying company's voting stock for 12 months before payment of the dividend, 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%
Uruguay Effective January 1, 2012 5% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital 15% 0% 10%
Uzbekistan 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 15% 0% 3% 5% for literary or artistic copyrights or broadcasting royalties
Venezuela Effective January 1, 1997 5% where the payee is a company (excluding a partnership) holding at least 15% of the paying company's capital 15% 0% 5%
Vietnam Effective January 1, 1997 5% where the payee is a company (excluding a partnership) holding directly at least 70% of the paying company's capital 10% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% 10%
Zambia Effective January 1, 1971 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% 10%
Zimbabwe Effective January 1, 1987 10% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 20% 0% 7.50%
Serbia Effective January 1, 1988 15% 0% 10% The Yugoslavia treaty continues to apply.
Kosovo Effective January 1, 1988 15% 0% 10% The Yugoslavia treaty continues to apply.

Footnotes

  1. A 5.5% solidarity surcharge (the revenue from which is ringfenced for improving infrastructure supporting the welfare system in the former East Germany, post-reunification) is payable on income and distributions, including dividend, interest (where payable) and royalty payments.
  2. In the case of European Union countries, the EC Parent-Subsidiary Directive can reduce dividend withholding tax to 0%, subject to certain conditions. Non-resident corporations can apply to the Federal Central Tax Office for a 40% refund, bringing the dividend withholding tax rate down to the CIT rate of 15% (plus the solidarity surcharge, resulting in an effective 15.825% rate).
  3. Germany's default interest withholding tax rate is 0%. A treaty may stipulate a higher rate.
  4. In the case of European Union countries, the EC Interest and Royalties Directive can reduce royalties withholding tax to 0%, subject to certain conditions.
  5. The treaty specifies a different rate but the default rate is lower and would therefore apply.
  6. PLEASE NOTE: This table was last updated February 2015

 

 

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