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Agreements in force under the 'Double Taxation Treaties'
Some useful details of the 34 agreements in force are set out below. See also Company Structure.
|
| Country |
Project duration for permanent establishment purposes |
Maximum Tax Rates applicable in the country of source |
|
|
|
Dividends |
Interest |
Royalties |
|
| Barbados |
>6 months |
5% |
5% |
5% |
| Belgium |
>6 months |
5% &10% (a) |
10% |
0% |
| Botswana |
>>6 months |
5% &10% (b) |
12% |
12.5% |
| China |
>12 months |
5% |
10% |
10% |
| Croatia |
>12 months |
exempt |
exempt |
exempt |
| Cyprus |
>12 months |
0% |
0% |
0% |
| France |
>6 months |
5% & 15%(a) |
same rate as under domestic law |
15% |
| Germany |
>6 months |
5% & 15%(b) |
same rate as under domestic law |
15% |
| India |
>9 months |
5% & 15%(b) |
same rate as under domestic law |
15% |
| Italy |
>6 months |
5% & 15%(b) |
same rate as under domestic law |
15% |
| Kuwait |
>9 months |
0% |
exempt |
10% |
| Lesotho |
>6 months |
10% |
10% |
10% |
| Luxembourg |
>6 months |
5% & 10% (a) |
0% |
0% |
| Madagascar |
>6 months |
5% & 10% (b) |
10% |
5% |
| Malaysia |
>6 months |
5% & 15% (a) |
15% |
15% |
| Mozambique |
>6 months |
8%,10% & 15% (b)&(f) |
8% |
5% |
| Namibia |
>6 months |
5% & 10% (b) |
10% |
5% |
| Nepal |
>6 months |
5%, 10% & 15%(d) & (f) |
10% & 15% |
15% |
| Oman |
>6 months |
0% |
0% |
0% |
| Pakistan |
>6 months |
10% |
10% |
12.5% |
| Rwanda |
>12 monthx |
exempt |
exempt |
exempt |
| Senegal |
>9 months |
exempt |
exempt |
exempt |
| Seychelles |
>12 months |
exempt |
exempt |
exempt |
| Singapore |
>9 months |
0% |
0% |
0% |
| South Africa |
>9 months |
5% & 15% (a) |
exempt |
exempt |
| Sri Lanka |
>6 months |
5% & 10% (a) |
10% |
10% |
| Swaziland |
>6 months |
7.5% |
5% |
7.5% |
| Sweden |
>6 months |
5% & 15%(a) |
15% |
15% |
| Thailand |
>6 months |
10% |
10% & 15%(e) |
5% & 15%(c) |
| Tunisia |
>12 months |
exempt |
2.5% |
2.5% |
| UAE |
>12 months |
exempt |
exempt |
exempt |
| Uganda |
>6 months |
10% |
10% |
10% |
| United Kingdom |
>6 months |
10% & 15%(a) |
same rate as under domestic law |
15% |
| Zimbabwe |
>6 months |
10% & 20%(b) |
10% |
15%
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(a) Lower rates applies to companies holding at least 10% capital.
(b) Lower rates applies to companies holding at least 25% capital.
(c) Lower rates applies to companies holding at least 20% capital.
(d) Lower rates applies to companies holding at least 15% capital.
(e) Lower rates applies if paid to any Bank carrying on a bona fide banking business.
(f) Higher rates applies to companies holding investment other than portfolio investment.
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