(see Taxable income and Tax rates.)

Domestic

Payments made by banks and financial institutions to local entities or individuals in the case of interests on bank deposits or financial investments are subject to income tax withholding.

Dividends paid by a local entity to a local individual are subject to income tax withholding. The tax rate applicable is 7 percent for the fiscal year 2020 and 13 percent as of FY 2021.

Foreign

Non-resident entities or individuals are taxed on their income considered to be of Argentine source.

The local payer is obliged to withhold the income tax at the time of the payment. Tax rates and presumptions of taxable income vary in connection with the type of payment made.

Tax treaties may reduce or eliminate withholding of income tax.

Dividends, royalties and interest

Generally, a 30-percent withholding tax rate applies to dividends (unless an exemption is available under domestic law (for example, dividends paid out of taxed profits – or DTA) and royalties and 10 percent for interest, which may be exempted under Australia's domestic law or reduced under a DTA.

The concessional withholding tax treatment for dividends, royalties and interests continue to be available under a DTA that is modified by the MLI, provided that the relevant integrity measures (eg, the Principal Purpose Test) are satisfied.

Crucially, the ATO has recently released a draft taxation ruling (TR) 2024/D1 which sets out the ATO’s views on when amounts paid from Australia under a ‘software arrangement’ are subject to royalty withholding tax. This draft TR represents a significant rewrite of the ATO’s previous rulings on this matter. 

Service fees

Generally, no withholding tax applies to service fees, unless the services fees are regarded as royalties. Importantly, TR 2024/D1, which could potentially apply to recharacterize certain fees as royalties if they are deemed to be consideration for the usage of intellectual property.

Withholding Tax

With regard to dividend distributions, see the explanations above. Regarding interest, no withholding tax becomes due in Austria, as long as the beneficial payee is a corporate entity or an individual, resident in a state with whom Austria has automatic exchange of information (otherwise withholding tax of 25 percent or 27.5 percent may become due). Royalties are subject to 20 percent withholding tax, subject to tax treaty limitation or limitation according to the EU Interest and Royalty Directive.

Exit Taxation

In the case of a transfer of assets that formed part of a business from Austria to a foreign country (eg, allocation of assets to a foreign branch), 25 percent latent capital gains generally are taxed at the time of the transfer. The same applies if the Austrian taxing rights regarding an asset are lost due to other circumstances. In case these assets are transferred to and taxing rights are lost vis-à-vis an EU/EEA member state, it is possible to apply for a payment by instalments (ie, 7 years for non-current assets and 2 years for currents assets).

Reporting Obligations under DAC 6

The aim of DAC 6 is to prevent aggressive tax planning by strengthening the control of the activities of tax intermediaries. According to the proposal, these intermediaries, such as tax advisors, accountants and lawyers who design and/or offer tax planning models, are to be obliged to report models that are considered potentially aggressive. By means of defined “hallmarks,” models are to be identified that must be reported to the tax authorities. The fact that a model must be notified does not mean per se that it is harmful, but only that it may be of interest to the tax authorities to examine it more closely. While some models have perfectly legitimate purposes, the aim is to identify those where this is not the case.

The reportable tax arrangements must be reported to the competent national authority within 30 days. The Member States are in turn to be required to exchange the information thus obtained automatically among themselves via a central database. Member States would be obliged to impose penalties on intermediaries who do not comply with the transparency rules.

Member States had until December 31, 2019 to implement the Directive into national law. The new reporting requirements apply from July 1, 2020. Member States must then exchange information every 3 months, namely within 1 month of the end of the quarter in which the information was received. The first Automatic Information Exchange took place on October 31, 2020.

Hybrid Mismatch

As of January 1, 2020 and based on the provisions of EU Directives (ATAD and ATAD II), provisions on hybrid mismatch are in effect. These provisions define the tax treatment of cross-border hybrid mismatch arrangements. Hybrid mismatches are the consequence of differences in the legal characterization of 2 jurisdictions regarding payments (financial instruments) or entities that arise as a result of interaction between these 2 jurisdictions.

Dividends, royalties, interest, etc.

A 30 percent withholding tax applies to the payment of dividends, royalties and interest. Domestic law provides for reduced rates and exemptions in certain circumstances. The applicable rate may further also be reduced under an applicable double taxation treaty.

Service fees

Withholding tax may, under specific conditions, apply to service fees paid to non-residents, subject to certain conditions.

In general, payments made to non-residents are subject to WHT in Brazil. As a general rule, payments to non-residents for services rendered to Brazilian residents and payments to non-resident individuals as work compensation are subject to the general WHT at a 25 percent rate. However, interest, royalties and other fees that are not paid in connection to the provision of services are taxed at a 15 percent rate.

The WHT shall also be levied at a 15 percent rate over the provision of technical services, administrative assistance and other similar services, which do not involve transfer of technology.

Note that payments made to entities located at low tax jurisdictions are subject to the WHT at a 25 percent rate. Tax treaties may reduce or eliminate WHT.

Other taxes may be imposed on the local source of payment depending on the nature of the transaction.

Dividends, royalties, interest, rents, etc

A 25-percent withholding tax applies to dividends, certain royalties, interest payments to non-arm's length persons, rent, and certain other payments made by a resident corporation to a non-resident person, subject to reduction under an applicable income tax treaty.

Service fees

Withholding tax may apply to certain payments in respect of services rendered by a non-resident, particularly where the services are rendered in Canada, subject to reduction under an applicable income tax treaty.

The general WHT rate is 35 percent applicable to payments made to non-residents. Certain payments in exchange for services or other transactions may qualify for domestic reduced rates or for Double Tax Convention reduced rates.

Dividends, royalties, interest, rents, etc.

Chinese payers have the legal obligation to withhold tax when remitting dividends, royalties, interest, rents and other payments to foreign recipients.

Service fees

Service fees are subject to income tax in China if the foreign recipient has created an establishment or place (or a Permanent Establishment in a tax treaty context) in China. Where applicable, a Chinese payer of service fees may also be designated as the withholding agent by the PRC tax authority.

Payments to non-tax residents are subject to withholding tax at the following rates, among others:

• 20 percent for personal services, fees, royalties, lease and any other payment for the use of intellectual property.

• 20 percent for technical services, technical assistance and consultancy, either rendered in Colombia or abroad.

• 20 percent on interest payment for loans with a term less or equal to 1 year.

• 15 percent on interest payment for loans with a term exceeding 1 year or financial lease payments.

• 5 percent on interest payments on cross-border loan agreements that have a term equal to or greater than 8 years and are destined to public-private infrastructure projects under the conditions set in Law 1508 of 2012.

• 10 percent on capital gains.

• There is a general 15 percent withholding rate when the type of income has not an specific withholding tax rate.

Withholding tax rate on payments made to non-tax residents may be reduced under double taxation treaties.

Dividends, royalties, interest, rents, etc.

Under the general rule, dividend and royalty payments to a foreign company are subject to 20-percent withholding tax.

Withholding tax is not levied on a dividend payment to a company within the EU if such company holds more than10 percent of the shares in the paying company and fulfills the requirements in the EU parent subsidiary directive.

Withholding tax is also not levied on royalty payments paid to a company within the EU in accordance with the EU directive on the condition that the 25-percent direct or indirect holding threshold is met.

Finland does not levy withholding tax on interest except on a few rare occasions.

Special withholding rates apply to foreign persons working in Finland – for example, sportsmen and artists.

Finland has a treaty network with over 70 countries. The tax treaties typically lower the applicable statutory rates depending upon the type of income. Withholding tax for foreign companies on Finnish dividends under the respective tax treaty is typically – but not always – 5 percent when the recipient holds at least 25 percent of the shares of the company making the payment.

Service fees

Typically exempted from Finnish withholding tax.

Withholding tax may be reduced or eliminated by applicable tax treaties or EU directives. An increased withholding tax rate of 75 percent is levied on dividends, interest or royalties paid to a beneficiary or on an account located in a non-cooperative state or territory.

Dividends, interest, etc.

As a general rule, dividends paid to non-residents are subject to a 12.8-percent withholding tax for individuals or 25-percent withholding tax for companies. The Finance Act for 2018 provides that the withholding tax applicable to companies on dividend payments will be aligned to the French corporate tax rate as of January 1, 2020 (see Tax Rates).

Generally, no withholding tax is levied on French-source interest, provided it is arm's length.

Royalties and service fees

As a general rule, a withholding tax may be levied, at the same rate as the standard corporate income tax rate, on royalties and service fees paid to non-residents. See Tax Rates above.

Dividends, royalties, interest, rents, etc.

Dividends paid to non-resident companies: Generally, a rate of 26.375 percent applies (ie, 25 percent withholding tax, or WHT, plus 5.50 percent solidarity surcharge on WHT, although exemptions may be available under the EU Parent-Subsidiary Directive, if applicable). There is a reduction of WHT under most German tax treaties for qualified dividends. In addition, on the basis of domestic law, foreign corporations may claim a refund of 40 percent of the WHT, subject to certain substance requirements.

Interest paid to non-resident companies: Generally, there is no WHT, although certain exceptions apply.

Patent royalties and certain copyright royalties paid to non-resident companies: Generally, 15.825 percent WHT applies. Exemptions may be available under the EU Interest-Royalties Directive, if applicable. There is a reduction of WHT under most German tax treaties.

Service fees

Not applicable for this jurisdiction.

Dividends, royalties, interest, rents, etc.

Hong Kong does not impose withholding tax on dividends, interests or rents. The only withholding tax is on any payment made to a nonresident for the use of, or the right to use, certain intellectual property in Hong Kong, or outside Hong Kong where payments are deductible for a Hong Kong taxpayer. The general tax rate is 16.5 percent on the assessable profits, of which the first HKD2 million of profits of corporations will be lowered to 8.25 percent. When the payment is derived from an associate and the relevant intellectual property has once been owned by any Hong Kong taxpayer, the assessable profits are deemed to be 100 percent of the payment; in other circumstances, the assessable profits are generally deemed to be 30 percent of the payment. A double taxation arrangement may provide for a lower rate.

Service fees

Not applicable for this jurisdiction.

Dividends, royalties, interest, rents, etc.

There is no withholding tax on dividends, interests and royalties paid to resident and nonresident companies.

Dividends, including advance dividends, paid to individuals are taxed at the rate of 15 percent. Double taxation treaties operate to modify these rules, including reducing the rate of withholding taxes.

Service fees 

Not applicable for this jurisdiction.

Withholding tax at differing rates applies to royalties, interest, fees for technical services and other income paid by a domestic corporation to a foreign person, subject to reduction by an applicable income tax treaty.

Dividends, royalties, interest, rents, etc.

Withholding tax applies in Ireland at a rate of 20 percent, or 25 percent in the case of distributions. However, a number of domestic exemptions exist to remove the withholding obligation.

In the case of dividends, exemptions include where dividends are paid to:

• A company or person resident in an EU/treaty country and not under the control of Irish residents
• A company that is not resident in an EU/treaty country but is controlled by a person(s) who is/are resident in an EU/treaty country and which person(s) is/are not under the control of a person(s) not resident outside an EU/treaty country, or
• A listed company or a 75-percent subsidiary of a listed company.

Withholding taxes apply to the payment of patent royalties. An exemption from withholding tax exists for certain patent royalties paid to persons resident in the EU or a double tax treaty country. It is also possible to pay patent royalties to non-Irish, non-treaty persons free from withholding tax in certain circumstances.

A number of exemptions apply in relation to the payment of interest, such as:

• Interest paid by a company (in the ordinary course of a trade or business) to a company resident in an EU/treaty country (other than Ireland) where that jurisdiction imposes a tax which generally applies to interest receivable from foreign territories (except where such interest is paid to that company in connection with a trade or business which is carried on in Ireland by that company through a branch or agency)

• Cross-border interest payments between associated companies in the EU (25-percent ownership is required or at least 25 percent of each company is owned by a 3rd company)

• Interest paid to another Irish resident company where both Irish resident companies are members of the same group (51-percent relationship required)
• Interest paid by a company to an approved pension scheme and
• Interest paid on a quoted Eurobond.

Withholding tax must be deducted from rental payments made to non-residents unless the landlord uses an Irish resident agent to whom the rents are paid.

Service fees

Not applicable for this jurisdiction.

Dividends, royalties, interest, rents etc.

Israel imposes extensive tax withholding requirements according to which almost any payment is subject to tax withholding unless a valid certificate is obtained from the tax authorities. For example, dividends are subject to tax withholding at the rate of 25 percent to 30 percent and interest paid to a foreign corporation is subject to tax withholding at the corporate tax rate (currently 23 percent).These rates may be reduced under an applicable treaty.

Service fees

Withholding tax may apply to certain payments for services rendered by a non-resident, particularly where the services are rendered in Israel.

Dividends, royalties, interest, rents, etc.

Dividends paid to foreign entities are subject to ordinary withholding tax at the rate of 26 percent. Dividends paid to EU countries and EEA "white-listed" countries subject to corporate tax in their country of residence are subject to 1.20-percent withholding tax. A tax treaty can reduce the abovementioned rate.

Exemption from withholding tax is provided under the EU Parent-Subsidiary Directive on dividends paid to qualifying shareholders. Among the other requirements, the participation must be at least equal to 10 percent and must be held for at least 12 months.

Interest paid to non-resident entities is subject to 26-percent withholding tax. A tax treaty can reduce the abovementioned rate. The Interest and Royalties directive provides for an exemption on interest and royalties paid to qualifying EU shareholders or affiliate entities.

Royalties are subject to 30-percent withholding tax, generally applied on 75 percent of the amount of the royalties. Tax treaties and the EU Interest and Royalties directive can reduce or eliminate the withholding tax.

Service fees

In principle, no withholding tax is applied on service fees.

Dividends, royalties, interest, rents, service fees, etc.

Items of income (including dividends, royalties, interest, rent and service fees) paid to a foreign corporation are generally subject to Japanese withholding income tax at a rate of 20.42 percent (15.315 percent for bond interest). However, double tax treaties may grant a special concession to a resident individual or a resident corporation in a foreign jurisdiction. Some double tax treaties provide that a person with dual residence may be determined to be a person with single residence by mutual agreement between competent authorities. In order to enjoy benefits under double tax treaties, an application form must be filed with the relevant tax office before the first payment between parties is made.

Dividends, royalties, interest, rents, etc.

Dividends paid to a non-resident company generally are subject to withholding tax at 15 percent, unless the rate is reduced under a tax treaty.

No tax is withheld on dividends paid to a qualifying company under the EU parent-subsidiary directive (2003/123/CE), except if the transaction qualifies as an abuse of law under the general anti-abuse rule. The benefits of the directive have been extended to parent companies resident in non-EU tax treaty countries (under certain conditions).

Luxembourg does not levy withholding tax on royalties.

Luxembourg does not levy withholding tax on interest, except for interest payments to Luxembourg resident individuals, in certain cases. Nonetheless, profit-sharing bonds and debt instruments with remuneration linked to the issuer's profits are taxed as dividends (15 percent), and interest payments can be requalified into dividends (and are then subject to a 15-percent withholding tax) where a Luxembourg company is over-indebted in light of thin capitalization rules or where a Luxembourg company does not comply with transfer pricing regulations.

Interest payments made by Luxembourg resident paying agents to Luxembourg resident individuals are subject to a 20-percent WHT. There is an exemption from WHT if the amount due does not exceed EUR250. Where interest payments are made or credited by foreign paying agents located in a member state of the EU or in a state of the European Economic Area, the Luxembourg resident taxpayer may opt for a 20-percent WHT.

Service fees

Luxembourg does not levy withholding tax on service fees.

Dividends, royalties, interest, rents, etc.

(a) This is a final tax applicable to non-residents. Payments to tax havens are generally subject to a 40-percent withholding tax. (b) This rate can be reduced to 4.9 percent if certain requirements are met. (c) A reduced rate of 4.9 percent is granted each year to banks resident in treaty countries. (d) This tax applies to dividends paid out of profits generated after 2013.

Income Tax Treaties

These withholding rates may be reduced to under available Income Tax Treaties entered into by Mexico, and to the extent that the requirements provided in the relevant Income Tax Treaty and the MITL are met.

Service fees

Income received by a foreign resident from rendering services in Mexico may be subject to a 25-percent withholding tax rate under domestic rules. However, income tax treaties may reduce or eliminate this rate under specific circumstances. It is important to consider potential VAT implications.

Dividends, royalties, interest, rents, etc.

Under the terms of the generally applicable legislation, namely the IRPC Code, income of non-resident entities without permanent establishment in the national territory is taxed through definitive withholding tax at a single flat rate of 20 percent, with few exceptions such as income from rendering of telecommunications and international transport services, as well as assembly and installation of equipment made by such entities, which are subject to a single flat rate of 10 percent.

Until December 31 2025 the income derived from interest on external financing for agricultural projects is exempt from withholding tax and the income from the provision of services by non-resident entities to domestic agricultural companies will be subject to a reduced withholding rate of 10 percent.

The domestic withholding tax rate may be reduced if a tax treaty applies. The application of tax treaty is not automatic. The beneficiary of the income shall request its application.

Service fees

Withholding tax may apply to certain payments in respect of services rendered by a non-resident, particularly where the services are rendered in Mozambique, subject to reduction under a double taxation treaty, where applicable.

Dividends, royalties, interest, rents, etc

A 15-percent withholding tax applies to dividends paid by a domestic corporation to a person or entity. A domestic dividend withholding tax exemption applies on dividends paid to EU/EEA parent companies and parent companies in a 3rd country that has concluded a tax treaty with the Netherlands that contains a dividends clause, unless anti-abuse provisions apply.

Double taxation treaties operate to modify these rules, including reducing the rate of withholding taxes.

Withholding tax is generally reduced to 0 percent if the corporate shareholder has an interest of 5 percent or more in the subsidiary (domestic and EU/EEA), in line with the Parent-Subsidiary Directive.

As of January 1, 2021, the Netherlands will levy a conditional withholding tax of 25 percent (25.8 percent as of 2022) on outbound payments of interest and royalties to low-tax jurisdictions and in abusive situations.

Service fees

Not applicable for this jurisdiction. 

Dividends, royalties, interest, rents, etc.

Dividends

Under the general rule, a dividend payment to a foreign shareholder will be subject to 25-percent withholding tax.

Dividend payments to corporate shareholders resident in the EEA are exempt from withholding tax, provided that the shareholder conducts a real business activity in the relevant jurisdiction. Otherwise, the rate may be reduced under an applicable tax treaty.

Dividend payments to shareholders resident outside the EEA are subject to 25-percent withholding tax, unless the rate is reduced under an applicable tax treaty.

Documentation requirements apply in order to benefit from exemption from or reduced dividend withholding tax.

Service fees

Royalties, interests, rents, etc.

Interest, royalties and lease payments for certain types of tangible assets (eg, ships, rigs, planes) paid to related parties resident in low-tax jurisdictions outside the European Economic Area (EEA) are subject to a withholding tax of 15 percent.

Royalties, interests and lease payments to corporate shareholders resident in the EEA are exempt from withholding tax, provided that the shareholder conducts a real business activity in the relevant jurisdiction.

Norway does not levy withholding tax on service fees.

Non-resident entities are subject to withholding tax at the following rates:

• Interests from loans: 4.99 percent. However, this tax rate applies only if the borrower proves the effective entrance of the funds in the country and as long as the interest rate is not higher that LIBOR plus 7 points. In such case, the excess would be taxed with a 30-percent tax rate. On the other hand, all cases of loans between related parties the tax rate would be 30 percent. This includes back-to-back structures as well.
• Royalties: 30 percent
• Dividends: 5 percent
• Technical assistance services: 15 percent
• Other income: 30 percent

From 2019, the requirements to apply the withholding tax exemptions and reduced withholding tax rates based on EU law or the applicable double tax treaties have been extended and more formalized. In order to benefit from a reduced rate or full tax exemption in accordance with the new regulations, regardless of the value of payments made, payers are required to exercise “due diligence.”

On 1 January 2022 the new withholding tax collection mechanism (pay and refund) entered into force. If the total amount of payments to the same recipient in a given tax year exceeds PLN2 million, the payer will be obliged to calculate, collect and pay the withholding tax using the standard rates set out in the CIT Act (19 to 20 percent), with a right to apply for a tax refund to the tax authority if the payment qualifies for an exemption or a reduced WHT treaty rate. However, the pay and refund mechanism is narrowed to intra-company passive payments of interests, royalties, dividends.

A motion can be filed with the relevant tax authority to apply the WHT exemption and avoid paying WHT on these payments within 36 months from date of receiving the tax authorities’ opinion.

An alternative procedure that could lead to relief from an obligation to collect WHT is a submission of statement by the management board of the tax remitter (i.e. Polish entity paying interest) confirming that all conditions have been met to use an exemption/diminished WHT rate.  However,  filing of the aforementioned statement carries the risk of criminal liability of the member of the management board in case it will appear that such conditions in fact were not met.

Dividends

The general withholding tax (WHT) for dividends is 19 percent. The WHT rate may be reduced by specific provisions of the applicable income tax treaty or an exemption based on the EU Parent Subsidiary Directive may be available. WHT is payable monthly by the 7th day of each month for preceding month. The exemption is not available if the dividend distribution is aimed at tax avoidance.

Royalties and interest

A 20-percent withholding tax applies to royalties, interest and other passive income paid by a domestic corporation to a foreign person, subject to reduction or elimination by an applicable income tax treaty or regulations based on the EU Interest Royalties Directive. WHT is payable monthly by the 7th day of each month for the preceding month. The exemption is not available if the royalty or interest distribution is aimed tax avoidance.

Intangible services

A 20-percent withholding tax applies to fees for intangible services paid to foreign recipients, like management fees or fees for advisory, legal, marketing, accounting, recruitment services or guarantees, the tax may be reduced based on the relevant tax treaty. The payments for intangible services are excluded from the pay and refund mechanism and therefore such payments will not be included in the limit of payments of PLN2 million, above which this mechanism applies.

Dividends, royalties, interest, rents, etc

Dividends paid to a foreign entity are subject to withholding tax at a rate of 25 percent (35 percent if paid to a resident of a black-listed country or if paid or made available in accounts in the name of 1 or more holders acting on behalf of undisclosed 3rd parties). The withholding tax rate may be reduced under a tax treaty. Dividends are not subject to withholding tax in the case of qualified participations (generally, 10 percent or more equity interest held for at least 1 year), subject to additional requirements.

Interest paid to a foreign entity is subject to withholding tax at a tax rate of 25 percent (35 percent if paid to a resident of a black-listed country or if paid or made available in accounts in the name of 1 or more holders acting on behalf of undisclosed 3rd parties). The withholding tax rate may be reduced under a tax treaty. Interest is not subject to withholding tax if the requirements under the EU Interest & Royalty Directive are met.

Royalties paid to a foreign entity is subject to withholding tax at a tax rate of 25 percent (35 percent if paid to a resident of a black-listed country or if paid or made available in accounts in the name of 1 or more holders acting on behalf of undisclosed 3rd parties). The withholding tax rate may be reduced under a tax treaty. Royalties are not subject to withholding tax if the requirements under the EU Interest & Royalty Directive are met.

Other payments made to foreign entities may be subject to withholding tax. The general tax rate is 25 percent.

Service fees

Withholding tax may be applied to service fees if the services are performed or used in Portugal (subject to treaty limitations).

Dividends, royalties, interest, rents, etc.

An 8 percent withholding tax applies to dividends and a 16percent withholding tax applies to royalties, interest, commission and other taxable income paid by a Romanian tax resident to a foreign person, subject to reduction or elimination by an applicable tax treaty.

An increased 50-percent tax rate applies for payments made under certain conditions and when income is paid in respect of transactions that qualify as artificial.

Dividends, interest and royalties could be exempt from withholding tax when paid to a resident of another EU member state provided the minimum holding criteria and specific conditions referring to the legal and fiscal status of the payer and the beneficiary of the income are equally met.

Service fees

Withholding tax of 16 percent may apply to fees for management and consultancy services and for other services if performed in Romania.

Dividends, royalties, interest, rents, etc.

Certain items of passive income (including dividends, royalties and interest) paid to a nonresident are generally subject to Russian withholding profits tax at a rate of 20 percent (15 percent for dividends).

Following the instruction by the Russian president voiced on March 25, 2020, the Russian Ministry of Finance have commissioned work to revise the withholding tax rate on dividends and interests paid to bank accounts in certain “transit” jurisdictions. It is planned that the unilateral rate will be 15 percent as opposed to the current reduced tax rates available under applicable double tax treaties.

The change announced by the president will require amendments to the existing double tax treaties. It was also noted that, if foreign countries do not cooperate, Russia will unilaterally withdraw from the consequent double tax treaty. Currently, Russia has notified Cyprus, Malta and Luxembourg on the proposed changes to the respective double tax treaties.

Service fees

Generally, service fees are subject to profits tax in Russia if such fees are attributed to a permanent establishment of a foreign recipient in Russia.

Reduced tax rates or full protection from withholding tax may be available under an applicable double tax treaty.

Fees earned from rendering of services that are physically provided from locations outside Russia are not deemed to be Russian-sourced. Accordingly, they are not subject to a 20-percent Russian profits tax at source, irrespective of availability of a relevant treaty.

Singapore does not levy any withholding tax on dividends paid by Singapore tax resident companies.

Interest, commissions, fees or other payments to non-residents, in connection with any loan or indebtedness, are subject to a final withholding tax of 15 percent on the gross amount (assuming the non-resident does not have a PE in Singapore), unless reduced under a tax treaty or exempt under domestic concessions or tax incentives. Any other interest paid to non-resident companies that do not qualify for the final rate or an exemption are taxed at the prevailing corporate tax rate of 17 percent.

Royalties paid to non-residents are generally subject to a final withholding tax of 10 percent on the gross amount of the royalty (assuming the non-resident does not have a PE in Singapore), unless reduced under a tax treaty or exempt under a domestic concession. Any other royalty paid to non-resident companies that do not qualify for the final rate are taxed at the prevailing corporate tax rate of 17 percent.

Payments to non-residents (other than individuals) for technical services rendered in Singapore are subject to 17 percent withholding tax (which is not a final tax), unless the rate is reduced under a tax treaty.

Dividend, royalties, interest and foreign entertainment withholding taxes apply.

A 20-percent withholding tax applies to dividends, whereas the other withholding taxes are imposed at a rate of 15 percent.

Withholding taxes may be reduced in terms of tax treaties.

The payer of interest, dividends, business income, other income, etc. should withhold taxes in accordance with their respective withholding tax rates. Tax treaties can reduce or eliminate these taxes when the income is paid to a foreign person.

Dividends, royalties, interest, rents, etc.

A 19-percent withholding tax applies to dividends and interest paid by a domestic corporation to a foreign person. Royalties are subject to a 24-percent withholding tax, except for payments made to EU residents which are subject to a 19-percent withholding tax. These rates could be subject to reduction by an applicable Double Tax Treaty.

Under the EU Parent-Subsidiary Directive and the EU Interest and Royalties Directive, dividends and royalties paid to an associated company may qualify for an exemption. In addition, as a general rule, interest payments to EU residents are exempt from withholding tax in Spain.

Service fees

As a general rule, withholding tax only applies to service fees if the services are performed in Spain, provided that a double tax treaty does not apply.

Dividends, royalties, interest, rents, etc

Under the general rule, a dividend payment to a foreign shareholder is subject to 30-percent withholding tax. However, domestic law contains exemptions from withholding tax under certain conditions:

Exemption 1

Withholding tax should not be levied on a dividend payment to a legal person within the EU if such person holds more than 10 percent of the shares in the paying company and fulfills the requirements in Article 2 of the Parent Subsidiary Directive.

Exemption 2

Withholding tax should not be levied on a dividend payment if the shares are unlisted or, if listed, the recipient holds at least 10 percent of the voting rights in the paying company. The share must have been held for at least 1 year at the time of the dividend payment if it is a business-related share that is listed. The recipient must also fulfill the definition of being a "foreign company" and be the foreign equivalent of a Swedish limited liability company. Further, for the exemption to apply, it is required for the dividend payment to have been tax exempt under the participation exemption regime should the shareholder have been a Swedish limited liability company.

A rule from January 1, 2016 in the Swedish Withholding Tax Act states that dividends from a Swedish subsidiary to a foreign company should not be tax exempt if certain conditions are met.

Sweden does not levy withholding tax on interest or royalty payments. However, royalty payments made to non-residents are deemed to derive from a Swedish business and are taxed as income from a permanent establishment in Sweden. Thus, the recipient is taxed in Sweden on the net royalty income at the ordinary corporate income tax rate of 20.6 percent. Sweden's right to tax royalties may be reduced under an applicable tax treaty.

Service fees

Not applicable for this jurisdiction.

Dividends, royalties, interest, rents, etc.

Swiss withholding tax is a federal tax levied on certain types of investment income from Swiss sources, including dividends and interest payments. Royalties, management fees and interest payments on certain loans are in general not subject to withholding tax. The withholding tax is levied at a flat 35 percent rate, subject to reduction under any of the various income tax treaties Switzerland has concluded. Switzerland signed and ratified the Multilateral Instrument (MLI).

Service fees

Service fees are not subject to withholding tax.

Dividends, royalties, interest, rents, etc

In general, Taiwan-source dividends are subject to withholding tax at 21 percent, while other profit distributions, interest income, rental income and royalties earned by foreign companies are subject to withholding tax at 20 percent. However, Taiwan has entered into tax treaties with 34 countries, resulting in reduced tax rates.

Service fees

Service fees are normally subject to a 20-percent withholding tax if considered Taiwan-source income, though apportionment of fees (ie, where only part of the service fees is Taiwan-source income) is possible. A company with a head office outside Taiwan and which is engaged in technical services in Taiwan for which the costs and expenses are difficult to calculate may apply for approval to treat 15 percent of its total service fees as income derived in Taiwan, which, if taxed at the 20-percent rate, would effectively reduce the tax rate to 3 percent.

Dividends, royalties, interest, rents, etc

A 10-percent withholding tax applies to dividends paid to the non-resident companies.

The rate applicable to the interest on loans paid to an international institution or a foreign bank with the status of a financial entity is 0 percent. However, interests on loans from other non-resident entities are subject to an applicable rate of 10 percent.

The non-resident companies are required to apply withholding tax on rental income. This withholding tax rate is set at 20 percent.

A 20 percent withholding tax applies to royalties, paid to a non-resident.

The rates mentioned above may be subject to reduction under an applicable tax treaty.

Service fees 

Payments for professional services (eg, technical assistance, consulting, design or supervision) are subject to a 20-percent withholding tax. This rate may be subject to reduction under an applicable tax treaty.

The deduction rate is increased to 80 percent to be applied to income and gains derived from certain services rendered abroad.

Dividends, royalties, interest, rents, etc 

Dividends, royalties, interest and rents paid to a nonresident are subject to standard 15-percent withholding tax unless relief is granted by relevant double tax treaty. Other rates are envisaged for certain types of income such as insurance payments or freight.

Service fees 

Generally, service fees payable to nonresidents are exempt from withholding tax. Exceptions are:

• Engineering fees, which are subject to a 15-percent withholding tax (avoided under most double tax treaties in force for Ukraine)
• Advertising fees, which are subject to a 20-percent withholding tax paid on top of income and at the expense of Ukrainian company (and which is not relieved under double tax treaties)

Not applicable for this jurisdiction.

Dividends, royalties, interest, rents, etc 

There are no withholding taxes on dividends paid by a UK company to any shareholder.

A 20 percent withholding tax applies to royalties, yearly interest, certain qualifying annual payments and rents paid by a UK letting agent or tenant to a nonresident company, subject to reduction under an applicable income tax treaty and, in the case of rents, the nonresident landlord scheme.

It is sometimes possible to structure loan arrangements so that payments equivalent to interest fall outside the definition of yearly interest (such as the use of discounted bonds). Interest payable on a loan instrument listed on a recognized stock exchange is not subject to any withholding.

Service fees 

Certain payments for construction services provided in the UK are subject to a form of withholding tax at either 30 percent or 20 percent unless the party providing the service is registered for gross payment.

Dividends, roytalties, interest, rents, etc.

A 30-percent withholding tax applies to dividends, royalties, interest, rents and other FDAP income paid by a domestic corporation to a foreign person, subject to reduction or elimination by an applicable income tax treaty.

Service fees 

Withholding tax may apply to service fees paid to a foreign person if the services are performed in the US.

A withholding tax on dividends is payable at a rate of 15 percent in respect of unlisted securities and 10 percent in respect of listed securities; however, the existence of a DTA may reduce the rate to 5 percent where the shareholder receiving the dividend holds 25 percent shareholding in the relevant company paying the dividend, and 10 percent in all other cases.

Zimbabwe has entered into comprehensive DTAs with the following countries: Botswana, Bulgaria, Canada, France, Germany, Malaysia, Mauritius, Namibia, Netherlands, Norway, Poland, South Africa, Sweden, the UK and China.

Zimbabwe has pending DTAs with Indonesia, Namibia, Singapore, the Seychelles, Switzerland, Tanzania, Thailand, Tunisia, Yugoslavia, Zambia, the Democratic Republic of Congo, Iran, and Serbia and Montenegro.

Nonresident withholding tax on payments made by branch office to foreign head office in respect of head office charges is levied at a rate of 15 percent.

Withholding tax on interest is levied on residents at the rate of 5 percent (for a fixed-term deposit with a tenure of at least 90 days) or 15 percent. Nonresident investors, however, are currently exempt from withholding tax on interest.

Nonresident withholding tax on royalties is levied at the rate of 15 percent.

Nonresident withholding tax on management fees is levied at the rate of 15 percent. Nonresident withholding tax on remittances is levied at the rate of 15 percent.