Various tax treaties
Double Taxation Treaties (DTTs) between the following markets were signed and came into force with the rates as indicated in the following table:
Markets | Date signed (conclusion date) | Date in force | Applicable (effective date) | General DTT | |
Rates (%) | |||||
Equities | Debt | ||||
China – Italy | 23.03.2019 | 19.02.2025 | 01.01.2026 | 10% | 0%a |
Czech Republic – Montenegro | 20.02.2024 | 30.01.2025 | 01.01.2026 | 10% | 10% |
Mauritania – Saudi Arabiac | 02.12.2018 | 01.01.2025 | TBC | TBC | TBC |
a. The 0% withholding tax rate is applicable in the source country if (a) the payer of the interest is the government of that country or a local authority thereof; (b) the interest is paid to the government of the other country or political subdivisions, local authorities thereof, the Central Bank of the other country, or any public entity or any entity the capital of which is wholly owned by the government of that other country, or paid on loans guaranteed or insured by the government of that other country, or political subdivisions, local authorities thereof, the Central Bank of the other country or any public entity or any entity the capital of which is wholly owned by the government of the other country. Note that the Protocol of the DTT outlines the list of public Chinese and Italian entities that fall in-scope of this exemption.
b. The 10% withholding tax rate is generally applicable to other cases.
c. According to the IBFD site, the DTT between Mauritania and Saudi Arabia entered into force on 1ST January 2025. However, based on publicly available information in consultation with our Saudi EY Team, we confirm that the DTT is not yet available. We will keep you posted as soon as we receive further updates.
Terminated DTTs
Markets | Effective date of termination | |
Greece – United Arab Emirates | 18.12.2024 | |
Our Market DTT information will be updated in due course to reflect the new treaties.
This Taxflash is intended to provide clients with general information gathered from different sources that are generally believed to be reliable. LuxCSD S.A. does not guarantee the accuracy or completeness of the information and does not undertake to keep it up to date. Use of the information made available in this Taxflash is at the client’s own risk and LuxCSD S.A., its subsidiaries and affiliates expressly disclaim any liability for any errors or omissions reflected herein. The information in this Taxflash does not constitute legal or tax advice. |