Global Withholding Tax Alert - EY… · India April 1, 2017 Statutory Capital gains Long-term...

Global Withholding Tax Alert For immediate action Ref: 2017/390 Date: 12/21/17

Reminder: Withholding Tax Rate Changes in 2017 and Other Changes Effective in 2018 (REVISED)

We would like to take this opportunity to remind Global Withholding Tax Reporter (GWTR) subscribers of certain changes that took effect in late 2017, as well as those that will take effect in 2018. For GWTR purposes, the information provided in this Alert generally includes statutory, statute of limitations and treaty changes affecting dividends, interest and capital gains.

As the information provided below is a brief summary of the respective changes, more detailed information

can be obtained in the GWTR.

1 2017 Year end wrap-up

Table of contents Statutory and procedural changes ................................................................................................................. 3

Argentina ................................................................................................................................................. 3

Australia .................................................................................................................................................. 3

Bahrain .................................................................................................................................................... 3

Belgium ................................................................................................................................................... 3

Brazil ....................................................................................................................................................... 3

Chile ........................................................................................................................................................ 3

Colombia .................................................................................................................................................. 4

Czech Republic ......................................................................................................................................... 4

Denmark .................................................................................................................................................. 4

Ecuador ................................................................................................................................................... 4

Egypt ....................................................................................................................................................... 4

Estonia .................................................................................................................................................... 4

France ..................................................................................................................................................... 4

Germany .................................................................................................................................................. 5

Ghana ...................................................................................................................................................... 5

Hungary ................................................................................................................................................... 5

Iceland ..................................................................................................................................................... 5

India ........................................................................................................................................................ 6

Israel ....................................................................................................................................................... 6

Italy ......................................................................................................................................................... 6

Kenya ...................................................................................................................................................... 6

Latvia ...................................................................................................................................................... 6

Lebanon ................................................................................................................................................... 6

Luxembourg ............................................................................................................................................. 7

Morocco ................................................................................................................................................... 7

Norway .................................................................................................................................................... 7

Oman ....................................................................................................................................................... 7

Pakistan ................................................................................................................................................... 7

Philippines ............................................................................................................................................... 7

Poland ..................................................................................................................................................... 8

Qatar ....................................................................................................................................................... 8

Romania .................................................................................................................................................. 8

Saudi Arabia ............................................................................................................................................. 8

Sri Lanka .................................................................................................................................................. 8

South Africa ............................................................................................................................................. 8

Switzerland .............................................................................................................................................. 8

Taiwan ..................................................................................................................................................... 9


Tunisia ..................................................................................................................................................... 9

Ukraine .................................................................................................................................................... 9

United Arab Emirates ................................................................................................................................ 9

Treaty changes ........................................................................................................................................... 10

Entry into force — treaties ........................................................................................................................ 10

Entry into force — protocols ..................................................................................................................... 20

GWTR contact information........................................................................................................................... 22

Statutory and procedural changes




Country Change type Category Effective date Comments

Argentina

Statutory Dividends

Interest

Capital gains

January 1, 2018 Argentina’s comprehensive tax reform (Law No. 27,430, enacted through publication in the Official Gazette on December 29, 2017) introduces amendments to the dividend withholding tax rate, capital gains tax and establishes certain exemptions for nonresident investors.

Please see Tax Alerts 2017/401, 2017/386 and 2017/339 for details.

Australia

Statutory Capital gains July 1, 2017 Withholding rate increased from 10% to 12.5% on the sale of taxable Australian real property (TARP) and the withholding threshold was reduced from AUD 2,000,000 to AUD 750,000.

Please see Tax Alert 2017/190 for details.

Bahrain

Statutory VAT January 1, 2018 A 5% VAT was introduced based on the Gulf Cooperation Council Value Added Tax Framework Agreement.


Belgium

Statutory Dividends January 1, 2018 Belgium introduced a withholding tax exemption applicable to dividends distributed in respect of participations of less than 10%, but with an acquisition value of at least EUR 2.5 million in companies of which the shares qualify for the Belgian participation exemption regime if certain requirements are met.

Brazil

Statutory Tax havens January 1, 2018 On December 26, 2017, the Brazilian Internal Revenue Service published Normative Instruction 1,773/17, excluding Singapore, Costa Rica and Madeira Island from the list of black list (tax haven) jurisdictions.


Chile

Statutory Dividends December 1, 2017 Treaty benefits on dividend withholding tax for those treaties not yet in force was extended for two years through December 31, 2021.

Chile

Statutory Tax havens November 20, 2017 Chile's Internal Revenue Service published Resolution No. 124/2017 on November 20, 2017, which provides a preliminary list of 150 countries and jurisdictions considered to have a preferential tax regime under Article 41H for the purpose of application of rules included in the Income Tax Law.

https://www.globaltaxreporter.com/Knowledge/News.aspx?AlertID=61979






https://en.wikipedia.org/wiki/File:Flag_of_Australia.svg

https://en.wikipedia.org/wiki/File:Flag_of_Argentina.svg






Colombia

Statutory Dividends January 1, 2018 The following withholding tax changes apply to dividends paid from January 1, 2018 (i.e., profits generated in 2017):

5% applies to dividends distributed out of the distributing entity’s previously taxed profits that are paid outside of the portfolio regime;

35% applies to dividends paid from profits not taxed at the corporate level that are paid outside of the portfolio regime, and then a 5% withholding tax applies over the remaining balance.


Czech Republic

Procedure

Reclaims July 1, 2017 The statutory deadline for filing a reclaim for excess tax withheld was extended from within 60 days to two years from the date of the income payment effective July 1, 2017. There is uncertainty around the application of the effective date.


Denmark

Statutory Dividends N/A The European Union (EU) Advocate General issued his opinion that the Danish rules on withholding tax on dividends to nonresident mutual investment funds are in breach of the fundamental EU rights of freedom.

EU and third country investment funds and investment fund managers should consider filing protective claims for refund of Danish dividend withholding tax.

Please see Tax Alerts 2017/394 and 2016/338 for details.

Ecuador

Statutory Tax havens

2017 Ecuador's Internal Revenue Service amended the tax haven list to include Hong Kong.

Certain entities in Costa Rica, the Netherlands, New Zealand and the United Kingdom were also added to the tax haven list.


Egypt

Statutory Capital gains

Stamp duty

June 19, 2017 The capital gains tax exemption was extended for an additional three years through May 17, 2020.

A stamp duty tax was also introduced on buy/sell transactions for all shares whether listed or not. The rate is 0.125% on both the buyer and seller. This rate will increase to 0.150% from June 1, 2018 and to 0.175% from June 1, 2019.

Please see Tax Alerts 2017/215, 2017/187, 2017/167 and 2017/162 for details.

Estonia

Statutory Dividends January 1, 2018 The Bill on Amendments to the Income Tax Act introduced a 7% withholding tax on dividend income paid to nonresident individuals from 2019, regardless of when the profits were earned if the Estonian company has paid the 14% corporate income tax on the relevant profits.

Dividends paid to nonresident corporate investors will continue to be tax-exempt, as well as the portion of the profits paid to nonresident individuals that were subject to the 20% corporate income tax rate.


France Statutory Dividends

Capital gains

FTT

January 1, 2018 On December 29, 2017, the France Finance Act for 2018 published in the Official Gazette, provides the following changes:

















dividend withholding tax rate reduction for nonresident individuals from 30% to 12.8%;

reduction of standard capital gains rate for nonresident companies to 33.33%;

removal of intraday transactions from the scope of the Financial Transaction Tax ;

repeal of the 3% distribution tax.

Please see Tax Alerts 2018/3, 2017/392, 2017/379, 2017/357, 2017/325 and 2017/304 for details.

Germany

Procedure Dividends January 1, 2018 The German Federal Ministry of Finance issued a decree with regard to the status certificate that applies to foreign UCITS, corporate-type AIFs and mutual funds (e.g., US RICs and ETFs).

The status certificate provides for an upfront reduction in the statutory withholding tax rate from 26.375% to 15% provided certain requirements are met.

Please see Tax Alerts 2017/362, 2017/347, 2017/326, 2017/238 and 2017/234 for details.

Germany

Statutory Capital gains TBD On October 25, 2017, the German Federal Tax Court published a decision that 100% of the German capital gains are tax-exempt for non-German corporate sellers of shares that do not have a permanent establishment in Germany, even if the ownership is/was at least 1%. Additional guidance is expected.


Ghana

Statutory Capital gains March 15, 2017 -

December 31, 2021

The Budget implemented on March 15, 2017 provides a tax exemption on gains from the sale of securities listed on the Ghana Stock Exchange until December 31, 2021.


Hungary

Procedure Reclaims January 1, 2018 On November 21, 2017, the President of the Republic of Hungary signed into law new legislation that amends the procedural requirements with respect to refund claims filed with the tax authorities.

Iceland

Statutory Dividends

Interest

Capital gains

January 1, 2018 On December 30, 2017, the Iceland 2018 Budget was signed into law and is effective January 1, 2018

The new legislation provided for a 2% increase in the withholding tax rates for nonresidents as follows:

The withholding tax rate for dividend income paid to nonresident legal entities increased from 18% to 20%

The withholding tax rate for dividend income paid to nonresident individuals increased from 20% to 22%

The withholding tax rate for interest income paid to nonresident legal entities and individuals increased from 10% to 12% (income paid by the Icelandic Central Bank on behalf of the Government of Iceland remains tax-exempt.)

The withholding tax rate applicable to capital gains for nonresident legal entities increased from 18% to 20%

The withholding tax rate applicable to capital gains for nonresident individuals increased from 20% to 22%.




















India


April 1, 2017

Long-term capital gains tax on the sale of shares of an Indian private company decreased from 20% to 10%, with retroactive effect from April 1, 2012.


India

Statutory GST July 1, 2017 India’s comprehensive dual Goods and Services Tax (GST) has replaced the complex multiple indirect tax structure as of July 1, 2017.


Israel

Statutory Interest

Capital gains

January 1, 2018 Interest and capital gains tax rates decreased from 24% to 23%.


Italy

Statutory Tax havens April 18, 2017 An additional 11 countries were added to the Italian white list.


Italy

Statutory Capital gains January 1, 2018 The taxable base percentage of capital gains from qualified participations increased from 49.72% to 58.14% of the gain realized from January 1, 2018.


Kenya

Statutory Dividends

Interest

January 1, 2018 Dividends paid by Special Economic Zone (SEZ) enterprises will be tax-exempt and interest payable by a SEZ enterprise to a nonresident will be subject to a 5% withholding tax.


Latvia

Statutory Dividends

Interest

Capital gains

January 1, 2018 The Latvian Parliament adopted a new Corporate Income Tax Law that provides for an increase in the withholding tax rates for dividend and interest income from 15% to 20%. This applies to nonresidents domiciled in a tax haven and nonresident individuals, regardless of domicile. The withholding tax rate decreased from 30% to 20% for interim dividends.

The withholding tax rate applicable to capital gains for nonresident individuals increased from 15% to 20%.

The withholding tax rate on the sale of real estate or shares in a company, whose assets comprise directly or indirectly more than 50% Latvian real estate, increased from 2% to 3%.

Lebanon

Statutory Dividends

Interest

Capital gains

TVA

October 26, 2017

(withholding rate

changes); January 1,

2018 (TVA)

Law No. 64 for 2017 amended the following tax rates:

removal of the 5% withholding tax rate on dividend income (as a result, dividends are now subject to the standard rate of 10%);

gains on the disposal in Lebanese SARL companies (Limited Liability Companies) and bonds issued by Lebanese companies by a nonresident individual or entity are subject to an increased 15% capital gains tax;

the 5% withholding tax rate on interest income has been increased to 7%;














standard rate applicable to Taxe sur la valeur ajoutee (TVA) will increase from 10% to 11%.

Luxembourg

Treaty Collective investment vehicles

N/A The Luxembourg Tax Administration released an administrative Circular (Circular) that details the issuance of certificates of residence for Luxembourg undertakings for collective investment (UCIs).

The Circular also updates the list of tax treaties accessible to UCIs from a Luxembourg perspective.


Morocco

Statutory Capital gains January 1, 2018 Capital gains from the sale of unlisted shares for income exceeding MAD 1,000,000 increased from 30% to 31% due to the increase in corporate tax rate.

Norway

Procedure Dividend January 1, 2019

(postponed from

January 1, 2018)

Norway’s Ministry of Finance announced that its revised documentation requirements to benefit from a reduced dividend withholding tax rate at-source scheduled to enter into force on January 1, 2018 have been postponed until January 1, 2019.

Please see Tax Alerts 2017/388, 2017/376, 2017/353, 2017/338, 2017/321 and 2017/311 for details.

Oman

Statutory Dividends

Interest

February 27, 2017

Dividend and interest withholding tax rates for nonresidents increased from 0% to 10%.


Pakistan

Statutory Dividends

Capital gains

July 1 , 2017 The dividend withholding rate increased from 12.5% to 15% for filers

Capital gains tax rates of 15% for (filers) and 20% (non-filers) apply regardless of holding period for securities acquired on or after July 1, 2016

Please see Tax Alerts 2017/205, 2017/192 and 2017/173 for details.

Philippines


Stock transaction tax

Stamp duty

January 1, 2018 The Republic Act No. 10963 (i.e., the Tax Reform for Acceleration and Inclusion (TRAIN) Bill) was signed into law on December 19, 2017. It provides the following changes for nonresidents from January 1, 2018:

capital gains tax on unlisted shares increases from 5% to 15% on the first PHP 100,000 for nonresident individuals;

stock transaction tax on listed shares increases from 50% to 60% of 1% of the taxable base;

documentary stamp tax on sale or transfer of shares or certificates of stock increases from 0.375% to 0.75% on the par value;

documentary stamp tax on the original issuance of debt instruments increased from 1% to 1.5% on the par value.


Philippines

Procedure Dividends

Interest

June 26, 2017 Revenue Memorandum Order (RMO) No. 8-2017 prescribes the new procedure for claiming preferential tax treaty benefits on dividend and interest income, including the replacement of the Tax Treaty Relief




https://www.globaltaxreporter.com/Knowledge/News.aspx?Alertid=60690














Application (TTRA) with the Certificate of Tax Residence for Tax Treaty Relief Form (CORTT).


Poland

Statutory Capital gains January 1, 2018 Investors resident in a tax haven are subject to a 19% capital gains rate.

Qatar

Statutory VAT

January 1, 2018 The Qatar Council of Ministers announced the approval

of the Qatar VAT Law and Excise Law and Executive regulations, which establishes the standard VAT rate of 5% unless an exemption applies.


Romania


January 1, 2018 The capital gains tax rate for nonresident individuals will decrease from 16% to 10%.

Saudi Arabia

Statutory VAT January 1, 2018 The Saudi Arabian Government approved the VAT Law, which provides a standard VAT rate of 5%. However, certain goods and services may be subject to a 0% rate or an exemption. Please see Tax Alerts 2017/255 and 2017/239 for details.

Sri Lanka

Statutory Dividends

Interest

Capital gains

April 1, 2018 Dividend and interest withholding tax rates for nonresidents will increase from 10% to 14%.

A 10% capital gains tax is introduced on the sale of capital assets.

A capital gains tax exemption applies to gains from the sale of shares quoted on any stock exchanged published in the official list by the Sri Lanka Securities and Exchange Commission.


South Africa

Statutory Dividends

Capital gains

February 22, 2017

Dividend withholding tax rate increased from 15% to 20%.

Withholding tax on immovable property sales by nonresidents increased as follows:

from 5% to 7.5% for individuals

from 7.5 to 10% for companies

from 10% to 15% for trusts


Switzerland

Procedure US RICs September 2017 On September 7, 2017, the State Secretariat for International Financial Matters confirmed that third party-collected information (e.g., from a proxy solicitation firm) is acceptable to support the treaty eligibility of US RIC investors as it relates to recovering Swiss withholding tax.

















Taiwan

Statutory Dividends January 1, 2018 Dividend withholding tax rate increased from 20% to 21%.


Tunisia

Statutory Dividends

Interest

January 1, 2018 Dividend withholding tax rate increased from 5% to 10%.

Interest withholding tax rate increased from 5% to 10% on payments to nonresident banks.


Ukraine

Statutory Interest September 2017 The Ukrainian Parliament adopted Law No. 2146-VIII (Law). The Law amends the withholding tax exemption for interest income on government debt paid to nonresidents to include other income on state securities paid by the Ministry of Finance of Ukraine.

United Arab Emirates

Statutory VAT January 1, 2018 The United Arab Emirates Federal Government approved the VAT law, which provides a standard VAT rate of 5%.





T Treaty changes


Entry into force — treaties

Entry into force — Treaty

Country Country Treaty rates Signature date Entry into force date Effective date Comments

Argentina

Mexico

Dividends: 15%

Interest: 12%

0% rate applies to government or loan-related investments for interest. Please see Tax Alert 2015/799 for treaty summary.

Capital gains: 0% (general)

Domestic law rates apply to gains from immovable property.

November 4, 2015

August 23, 2017

January 1, 2018

First treaty between the two countries.


Austria

Iceland

Dividends: 15%

Interest: 0%


June 30, 2016

March 1, 2017

January 1, 2018



Belgium

Macedonia*

Dividends: 15%

Interest: 10%

An exemption applies to government-related investments for interest.


July 6, 2010 Jul 17, 2017 January 1, 2018

2010 treaty to replace the 1980 treaty.


Belgium

Uruguay

Dividends: 15%

An exemption applies to pension fund-related investments for dividends. Please see Tax Alert 2013/454 for treaty summary.

Interest: 10%

An exemption applies to government or pension fund-related investments for interest.



August 23, 2013

August 4, 2017 January 1, 2018



Brazil

Russia

Dividends: 15%

Interest: 15%

0% rate applies to government-related investments for interest.


November 22, 2004

June 16, 2017 January 1, 2018



*For GWTR purposes, these countries are covered as countries of investor only.















https://en.wikipedia.org/wiki/File:Flag_of_Argentina.svg

T Treaty changes


Entry into force — treaties Entry into force — Treaty


China

Romania

Dividends: 3%

An exemption applies to government-related investments for dividends. Please see Tax Alert 2016/422 for treaty summary.

Interest: 3%

An exemption applies to government or loan-related investments for interest.



July 4, 2016 June 17, 2017 January 1, 2018



Croatia

Kosovo*

Dividends: 10%

Interest: 5%



March 6, 2017 December 4, 2017

January 1, 2018



Cyprus

Ethiopia*

Dividends: 5%

Interest: 5%

An exemption applies to government-related investments for interest. Please see Tax Alert 2016/408 for treaty summary.


December 30, 2015

October 19, 2017

January 1, 2018 (Cyprus); July 8, 2018 (Ethiopia)



Cyprus

Iran*

Dividends: 10%

Interest: 5%




August 4, 2015

March 5, 2017 January 1, 2018



Cyprus

Jersey

Dividends: 0%

Interest: 0%

Capital gains: 0%

July 11, 2016 February 17, 2017

January 1, 2018



Ecuador

Belarus*

The English treaty text is not yet available.

January 27, 2016

August 16, 2017

January 1, 2018



Egypt

Saudi Arabia

Dividends: 10%

An exemption applies to government-related investments for dividends, interest and capital gains.

Interest: 10%


April 8, 2016 July 1, 2017 January 1, 2018



*For GWTR purposes, these are covered as countries of investor only.


















https://www.globaltaxreporter.com/Knowledge/Document.aspx?documentID=10113&bookID=271102961&productID=964&docType=1000









T Treaty changes




Domestic law rates apply to gains from the sale of shares.

Finland

Germany

Dividends: 15%

Interest: 0%


Domestic law rates apply to gains from immovable property. Please see Tax Alert 2016/410 for treaty summary.

February 19, 2016

November 16, 2017

January 1, 2018

2016 treaty to replace 1979 treaty.


Finland

Turkmenistan**

Dividends: 15%

Interest: 10%




December 12, 2015

February 10, 2017

January 1, 2018



Germany

Armenia*

Dividends: 10%

Interest: 5%

An exemption applies to government and loan-related investments for interest. Please see Tax Alert 2016/515 for treaty summary.



June 29, 2016 November 23, 2017

January 1, 2018



Germany

Turkmenistan*

Dividends: 15%

Interest: 10%

An exemption applies to government and loan-related investments for interest.



August 29, 2016

November 28, 2017

January 1, 2018



Hong Kong

Belarus*

Dividends: 5%


Interest: 5%




January 16, 2017

November 30, 2017

April, 1 2018 (Hong Kong); January 1, 2018 (Belarus)



Hong Kong

Latvia

Dividends: 10%


Interest: 10%

April 13, 2016 November 24, 2017

April 1, 2018 (Hong Kong); January 1, 2018 (Latvia);





























T Treaty changes







Hungary

Luxembourg

Dividends: 10%

Interest: 0%



June 23, 2015

January 26, 2017

January 1, 2018



Hungary

Oman

Dividends: 0%

Interest: 0%



November 2, 2016




India

Kenya

Dividends: 10%

Interest: 10%




July 11, 2016 August 30, 2017

January 1, 2018



Italy

Barbados*

Dividends: 15%

Interest: 5%




August 24, 2015

October 17, 2017

January 1, 2018



Italy

Romania

Dividends: 5%

Interest: 5%




April 25, 2015 September 25, 2017

January 1, 2018

























T Treaty changes




Japan

Latvia

Dividends: 10%

Interest: 10%



January 18, 2017

July 5, 2017 January 1, 2018



Japan

Slovenia

Dividends: 5%

Interest: 5%




September 30, 2016

August 23, 2017

January 1, 2018



Jersey


Dividends: 0%

Interest: 0%


April 20, 2016 February 15, 2017

January 1, 2018



Jordan

Saudi Arabia

The English treaty text is not yet available.

October 19, 2016

September 1, 2017

January 1, 2018



Jordan


Dividends: 7%

Interest: 7%

0% applies to government-related investments for dividends and interest.


April 5, 2016

January 10, 2017

January 1, 2018



Kenya

Iran*

Dividends: 5%

Interest: 10%




May 29, 2012 July 13, 2017 January 1, 2018 (Kenya); March 21, 2018 (Iran)




























T Treaty changes




Kenya

Korea

Dividends: 10%

Interest: 12%




July 8, 2014 April 3, 2017

January 1, 2018



Kenya


Dividends: 5%


Interest: 10%



November 21, 2011

February 22, 2017

January 1, 2018



Korea

Ethiopia*

Dividends: 8%

Interest: 7.5%




May 26, 2017 November 6, 2017

January 1, 2018 (Korea); July 8, 2018 (Ethiopia)



Kuwait

Kyrgyzstan*

Dividends: 0%

Interest: 0%


December 13, 2015

May 23, 2017 January 1, 2018



Kuwait

Lithuania

Dividends: 15%

A 0% rate applies to government-related investments for dividends.

Interest: 10%

A 0% rate applies to government-related investments for interest.


April 18, 2013 September 8, 2017

January 1, 2018



Luxembourg

Brunei*

Dividends: 10%

An exemption applies to government-related investments for dividends.

Interest: 10%



July 14, 2015 January 25, 2017

January 1, 2018




























T Treaty changes




Luxembourg

Ukraine

Dividends: 15%

Interest: 10%

A 5% rate applies to loan-related investments for interest. Please see Tax Alert 2016/483 for treaty summary.



September 6, 1997

April 18, 2017

January 1, 2018



Luxembourg

Uruguay

Dividends: 15%

Interest: 10%

A 0% rate applies to government or loan-related investments for interest. Please see Tax Alert 2016/10 for treaty summary.



March 10, 2015

January 11, 2017

January 1, 2018



Malta

Andorra*

Dividends: 0%

Interest: 0%



September 20, 2016

September 27, 2017

January 1, 2018



Malta

Ukraine

Dividends: 15%

Interest: 10%




September 4, 2013

August 28, 2017

January 1, 2018



Norway

Zambia

Dividends: 15%

A 0% rate applies to government-related investments for dividends.

Interest: 10%



December 17, 2015

August 9, 2017 January 1, 2018



Panama

Vietnam

Dividends: 12.5%

Interest: 10%




August 30, 2016

February 14, 2017

January 1, 2018



Portugal

Andorra*

Dividends: 15%

Interest: 10%


September 27, 2015

April 23, 2017 January 1, 2018


Please see Tax Alert



























T Treaty changes






2017/113 for details.

Portugal

Côte d’Ivoire*

Dividends: 10%

Interest: 10%




March 17, 2015

August 18, 2017

January 1, 2018



Portugal

Ethiopia*

Dividends: 10%

Interest: 10%




May 25, 2013 April 9, 2017 January 1, 2018 (Portugal); July 8, 2017 (Ethiopia)



Saudi Arabia

Turkmenistan*

Dividends: 10%

Interest: 10%




May 1, 2016 April 1, 2017 January 1, 2018



Singapore

Cambodia*

Dividends: 10%

Interest: 10%



Domestic law rates apply to gains from immovable property

May 20, 2016 December 29, 2017

January 1, 2018



Singapore

Ethiopia*

Dividends: 5%

Interest: 5%



August 24, 2016

December 8, 2017

January 1, 2018 (Singapore); July 8, 2017 (Ethiopia)



Singapore

Uruguay

Dividends: 10%

Interest: 10%



Domestic law rates apply to gains from immovable property

January 15, 2015





















T Treaty changes




Singapore

Sri Lanka

Dividends: 10%

Interest: 10%




April 4, 2014 December 31, 2017

January 1, 2018



South Africa

Cameroon*

Dividends: 15%

Interest: 10%




February 19, 2015

July 13, 2017 January 1, 2018



Slovak Republic

Armenia*

Dividends: 10%

Interest: 10%




May 15, 2015

February 1, 2017

January 1, 2018


Please see Tax Alert 2017/53 for details

Slovak Republic


Dividends: 0%

Interest: 10%




December 21, 2015

April 1, 2017 January 1, 2018



Sweden

Armenia*

Dividends: 15%

Interest: 5%




February 9, 2016

June 1, 2017 January 1, 2018




Andorra*

Dividends: 0%

Interest: 0%


An exemption applies to government-related investments for capital gains. Domestic law rates

July 28, 2015 August 1, 2017

January 1, 2018
































T Treaty changes




apply to gains from immovable property.


Kosovo*

Dividends: 5%

An exemption applies to government-related investments for dividends.

Interest: 5%




May 20, 2016 July 3, 2017 January 1, 2017



Liechtenstein*

Dividends: 0%

Interest: 10%



October 1, 2015

February 24, 2017

January 1, 2018




Macedonia*

Dividends: 5%

Interest: 5%

0% rate applies to government-related investments for dividends and interest. Please see Tax Alert 2016/200 for treaty summary.



October 26, 2015

February 8, 2017

January 1, 2018











Protocol changes


Entry into force — protocols Entry into force — protocols

Country Country Protocol rates Signature date Entry into force date Effective date Comments

Belgium

Mexico

Dividends: 10%

0% rate applies to pension fund-related investments for dividends. Please see Tax Alert 2015/531 for protocol summary.

Interest: 10%

5% rate applies to bank loan or bond-related investments for interest.

0% rate applies to pension fund, government or loan-related investments for interest.



August 26, 2013

August 19, 2017 January 1, 2018 Second protocol to amend the 1992 treaty.


Belgium

Switzerland

The protocol does not amend the general dividends, interest and capital gains rates. However, it does amend the exceptions of each of the aforementioned articles. Please see Tax Alert 2015/359 for protocol summary.

April 10, 2014 July 19, 2017 January 1, 2018 First protocol to amend the 1978 treaty.

Please see Tax Alert 2017/245 for details

France

Portugal

The protocol does not amend the general dividends, interest and capital gains rates. However, it does amend the limitation on benefits article. Please see Tax Alert 2017/308 for protocol summary.

August 25, 2016 December 1, 2017 January 1, 2018 Second protocol to amend the 1971 treaty.


Ghana

Netherlands

The protocol does not amend the general withholding rates applicable to dividends, interest and capital gains; however, it revises the entitlement of benefits pertaining to a company treated as a tax-exempt investment institution. Please see Tax Alert 2017/161 for protocol summary.

March 10, 2017 December 31, 2017

January 1, 2018 Second protocol to amend the 2008 treaty.


India

Singapore

Capital gains: amends cases in which domestic law rates apply.

December 30, 2016

February 27, 2017

February 27, 2017; April 1, 2017 (capital gains only)

Third protocol to amend 1994 treaty.


















Protocol changes


Entry into force — protocols Entry into force — protocols

Country Country Protocol rates Signature date Entry into force date Effective date Comments

Indonesia

Netherlands

Dividends: 15%

10% rate applies to pension fund-related investments for dividends. Please see Tax Alerts 2015/477 and 2015/470 for protocol summaries.

Interest: 10%

5% rate applies to loan-related investments for interest.

July 30, 2015 August 1, 2017 January 1, 2018 First protocol to amend the 2002 treaty.


Mexico

Spain

Dividends: 10%

An exemption applies to pension fund-related investments for dividends.

Interest: 10%

4.9% rate applies to bank loan or bond-related investments for interest.

0% rate applies to pension fund, government or loan-related investments for interest.


0% rate applies to pension fund-related investments for capital gains.


December 17, 2015

September 27, 2017

September 27, 2017

Second protocol to amend the 1992 treaty.


Netherlands

Uzbekistan*

The protocol does not amend the general dividends, interest and capital gains rates. However, it amends the definition of resident. Please see Tax Alert 2017/76 for protocol summary.

February 6, 2017

December 31, 2017

January 1, 2018 Second protocol to amend the 2001 treaty.












22 2017 Q1 wrap-up

GWTR contact information

If you have any questions about this Tax Alert, please reach out to:

Danielle Clark +1 203 674 3693

Stephanie Tanguay +1 617 585 0410

Lillian Chin +1 212 773 2679

Kelly Sullivan +1 212 773 0896

Michelle Wuest +1 949 437 0398

Michelle Yue +1 949 437 0228

Allison Schubert +1 212 773 7704

mailto:[email protected]





















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