Tax Guide

Treaty Partner

Ownership

Dividends

Interest *

Royalties

Albania

25

5/15 *

10

10

Algeria

-

12

10

10

Australia

-

D *

D *

D *

Austria

25

5/15 *

5/10*

10

Azerbaijan

0

12

10

10

Bahrain

25

10/15 *

10

10

Bangladesh

0

10

10

10

Belarus

25

10/15 *

10

10

Belgium

10

10/15 *

10 *

10

Bosnia-Herzegovina

25

5/15 *

10

10

Bulgaria

25

10/15 *

10

10

Canada

-

D *

D*

D *

China

-

10

10

10

Croatia

-

10

10

10

Czech Republic

-

10

10

10

Denmark

25

15 *

10 *

10

Egypt

25

5/15 *

10

10

Estonia

-

10

10

5/10 *

Ethiopia

-

10

10

10

Finland *

25

15 *

10 *

10 *

France

10

15*

10 *

10

Georgia

-

10 *

10 *

10 *

Germany *

-

D

D

D

Greece

-

15

10 *

10

Hungary

25

10/15 *

10

10

India

-

15

10 *

15

Indonesia

25

10/15 *

10

10

Iran

25

15 *

10

10

Ireland

25

5/10/15 *

10/15 *

10

Israel

-

10

10

10

Italy

-

15

10 *

10

Japan

25

10/15 *

10 *

10

Jordan

25

10/15*

10

12

Kazakhstan

-

10

10

10

Korea (R.O.K.)

25

15*

10*

10

Kuwait

-

10

10

10

Kyrgyzstan

-

10

10

10

Latvia

-

10

10

5/10 *

Lebanon

15

10/15 *

10

10

Lithuania

-

10

10

5/10*

Luxembourg

25

10/15 *

10 *

10

Macedonia

25

5/10 *

10

10

Malaysia

25

10/15 *

10 *

10

Moldova

25

10/15 *

10

10

Mongolia

-

10

10

10

Montenegro

25

5/15 *

10

10

Morocco

25

7/10 *

10

10

Netherlands

25

10/15 *

10 *

10

New Zealand

-

D *

D*

D *

Northern Cyprus (T.R.N.C.)

25

15 *

10

10

Norway *

25

15 *

10 *

10 *

Oman

15

10/15 *

10 *

10 *

Pakistan

25

10/15 *

10

10

Poland

25

10/15 *

10

10

Portugal

25

5/15 *

10 *

10

Qatar

25

10/15 *

10

10

Romania

-

15

10

10

Russia

-

10

10

10

Saudi Arabia

20

5/10 *

10

10

Serbia

25

5/15 *

10

10

Singapore

25

10/15 *

7.5/10 *

10

Slovakia

25

5/10 *

10

10

Slovenia

-

10

10

10

South Africa

25

10/15 *

10

10

Spain

25

5/15 *

10 *

10

Sudan

-

10

10

10

Sweden

25

15 *

10 *

10

Switzerland

-

D *

D *

D *

Syria

-

10

10

10/15*

Tajikistan

-

10

10

10

Thailand

25

10/15 *

10 *

15

Tunisia

25

12/15*

10

10

Turkmenistan

-

10 *

10

10

Ukraine

25

10/15 *

10

10

United Arab Emirates

25

5/10/12*

10

10

United Kingdom

25

15 *

10*

10

United States

10

15 *

10 *

5/10*

Uzbekistan

-

10

10

10

Topic

Details

Establishing HoldCo

Are advance rulings available? *

Yes

Are there restrictions on activities? *

No

Are there substance requirements?

No

Is capital duty payable?

Yes *

Is there a special tax regime for holding companies?

Yes *

Is there CFC or equivalent legislation?

Yes

Number of jurisdictions with active income tax treaties (minimum)

70

What is the effective corporate tax rate?

20%

Tax Treatment of Disposal of HoldCo

Is any tax payable in HoldCo country on disposal of HoldCo shares by a nonresident corporate shareholder?

Generally no *

Tax Treatment of Payments by HoldCo

Dividends: What is the (non-treaty / treaty) rate of withholding tax on dividends paid to nonresidents? *

Non-treaty: 15%; treaty: 5%-35%; EU/EEA: 5%-35%

Interest: Are there thin cap limits or other restrictions on interest deductibility?

Yes *

Interest: Is interest on loans to acquire subsidiaries deductible against HoldCo's profits?

Yes, for business purposes *

Interest: What is the (non-treaty / treaty) rate of withholding tax on interest paid to nonresidents? *

Non-treaty: 0%-10%; treaty: 5%-15%; EU/EEA: 0%-15% *

Liquidation payments: Is there withholding tax on liquidation payments?

Yes *

Taxation of HoldCo Income

Dividends: Does the foreign subsidiary have to meet any substance requirements? *

No

Dividends: Does the foreign subsidiary have to pay tax locally? *

Yes *

Dividends: How are dividends taxed?

Exempt/taxable with credit for foreign tax *

Dividends: What is the required holding period?

1 year

Dividends: What is the required percentage ownership?

10% of paid-in capital

Gains on disposal of participations: Are capital losses deductible?

No *

Gains on disposal of participations: Does the foreign subsidiary have to meet any substance requirements? *

No

Gains on disposal of participations: Does the foreign subsidiary have to pay tax locally? *

No

Gains on disposal of participations: How are gains on the sale of a subsidiary taxed?

Exempt provided certain conditions are satisfied *

Gains on disposal of participations: Is relief available for the write-down in value of subsidiaries?

No

Gains on disposal of participations: What is the required holding period?

2 years *

Gains on disposal of participations: What is the required percentage ownership?

10% *

Is joint taxation for groups available?

No