Further to our previous newsfeeds on this, the ratification procedure in both countries has been completed and the Double Tax Treaty (DTT) will enter in to force on 30 June 2023. It will generally apply as from 1 January 2024.
It is reminded that the treaty provides for the following Withholding Tax (WHT) rates:
Dividends: Nil as long as the beneficial owner (BO) is:
· a company holding directly at least 5% of the capital of the company paying the dividends, throughout a 365-day period that includes the day of the dividend payment;
· a recognised pension fund, which is exempt from any kind of income tax in the recipient state.In all other cases, the treaty provides for a maximum 15% WHT.
Interest: Nil as long as the recipient of the interest is the BO of the income.