Brief details of the DTT, which is based on the OECD Model Convention, are as follows:
Cross-border dividends payments are to be subject to 0% withholding tax at source if the beneficial owner is a company which holds directly at least 10% of the capital of the company paying the dividends.
In all other cases, dividends payments are to be subject to a 5% withholding tax.
Cross-border interest payments are generally to be taxable only in the country of the recipient of the income – i.e. no withholding tax being levied at source; subject to certain EU anti-avoidance provisions.
Royalty payments are generally to be taxable only in the country of the recipient of the income – i.e. 0% withholding tax at source.
Like many DTTs, provisions now cover gains resulting out of the sale of immovable property and property-rich companies, which are taxed in the country where the immovable property is located.
What Tech and Other Startups Need to Know About International Expansion
30 July 2019
The global economy is evolving quickly, and tech and other startups are looking beyond traditional expansion targets like the UK and China. Popular targets now include relatively low cost, talent-rich countries.…
Vistra Named Tier I Firm in 2019 eprivateclient Top Trust Companies
15 July 2019
Tracking International Business Trips to Protect Your Organisation
09 July 2019
Expanding into the UK: Why Would You Need a Service Address?
05 July 2019
Reporting requirements under Economic Substance – BVI
04 July 2019
03 July 2019