Double Taxation Treaty HandbookFor Corporate Withholding Tax

Double Taxation Treaty Handbook For Corporate Withholding Tax

© Copyright 2019 Standard Chartered Bank. All rights reserved. All copyright subsisting or arising out of this material belongs to Standard Chartered Bank and may not be reproduced, distributed, modified, adapted, transmitted or translated in any form or any way without the prior written consent of Standard Chartered Bank.

As-of date

Unless otherwise stated, the information contained in this guide is up to date as of 30 June 2019.

| A 1

Contents

SECTION A

IntereSt

SECTION B

DIvIDenDS

SECTION C

royAltIeS

Double Taxation Treaty Handbook For Corporate Withholding Tax

AfrICAAlgeria 4Angola

Botswana 6Cameroon

Cape Verde 8Congo

Egypt 10

Ethiopia 12Gabon

Gambia 14Ghana

Guinea 16Ivory Coast

Kenya 18Lesotho

Liberia 20Libya

Madagascar 22Malawi

Mauritius 24

Morocco 26Mozambique

Namibia 28Nigeria

Rwanda 30Senegal

Seychelles 32Sierra Leone

South Africa 34

Sudan 36Swaziland

Tanzania 38Tunisia

Uganda 40Zambia

Zimbabwe 42

AmErICASAntigua and Barbuda 44Argentina

Barbados 46Belize

Bolivia 48Brazil

Canada 50

Chile 52

Colombia 54Costa Rica

Cuba 56Ecuador

Falkland Islands 58Grenada

Guyana 60Jamaica

Mexico 62

Montserrat 64Panama

Paraguay 66Peru

St. Kitts and Nevis 68Suriname

Trinidad and Tobago 70

United States 72

Uruguay 74Venezuela

ASIA PACIfICAustralia 76

Bangladesh 78

Bhutan 80Brunei

Cambodia 82

China 84

Fiji 86

Hong Kong 88

India 90

Indonesia 92

Japan 94

Kazakhstan 96

Kiribati 98North Korea

South Korea 100

Kyrgyzstan 102Laos

Macau 104

Malaysia (including Labuan) 106

S E C T I O N A

Interest

Int

er

es

tIntereSt | DIvIDenDS | royAltIeS | A 3

Maldives 108Mongolia

Myanmar 110

Nepal 112

New Zealand 114

Papua New Guinea 116

Philippines 118

Singapore 120

Solomon Islands 122Sri Lanka

Taiwan 124Tajikistan

Thailand 126

Turkmenistan 128Tuvalu

Uzbekistan 130

Vietnam 132

EurOPEAlbania 134Andorra

Armenia 136

Austria 138

Azerbaijan 140

Belarus 142

Belgium 144

Bosnia and Herzegovina 146Bulgaria

Croatia 148Cyprus

Czech Republic 150

Denmark 152

Estonia 154

Faroe Islands 156Finland

France 158

Georgia 160

Germany 162

Greece 164Guernsey

Hungary 166

Iceland 168

Ireland 170

Isle of Man 172

Italy 174

Jersey 176Kosovo

Latvia 178

Liechtenstein 180Lithuania

Luxembourg 182

Macedonia 184

Malta 186

Moldova 188Monaco

Montenegro 190

Netherlands 192

Norway 194

Poland 196

Portugal 198

Romania 200

Russia 202San Marino

Serbia 204Slovakia

Slovenia 206

Spain 208

Sweden 210

Switzerland 212

Turkey 214

Ukraine 216

United Kingdom 218

mIDDlE EASTBahrain 220

Iran 222Iraq

Israel 224

Jordan 226

Kuwait 228Lebanon

Oman 230

Pakistan 232Palestine

Qatar 234

Saudi Arabia 236Syria

UAE 238Yemen

Double Taxation Treaty Handbook For Corporate Withholding Tax

Domestic Rate (%) Treaty Rate (%)

To › Algeria Angola

from Corp - Corp Corp - Bank Corp - Corp Corp - Bank

Australia 10 D D D D

Bangladesh 20 D D D D

Brunei 2.5 D D D D

Cambodia 14 D D D D

China 10CN1 0/7CN3 0/7CN3 D D

Hong Kong 0HK1 D D D D

India 5/20/30/40IN1 D D D D

Indonesia 20 15 0/15ID1 D D

South Korea 20KR1 10 0/10KR3 D D

Macau N/A D D D D

Malaysia (Incl. Labuan) 0/15MY1 D D D D

Philippines 20/30PN1 D D D D

Singapore 0/15SG1 D D D D

Sri Lanka 14 D D D D

Taiwan 15/20TW1 D D D D

Thailand 0/10/15TH1 D D D D

Vietnam 5 D D D D

Angola 10/15AN1 D D

Botswana 15 D D D D

Cameroon 16.5CM1 D D D D

Gambia 15 D D D D

Ghana 8 D D D D

Ivory Coast 18 D D D D

Kenya 0/15KE1 D D D D

Mauritius 0/15MU1 D D D D

Nigeria 10 D D D D

Sierra Leone 15 D D D D

South Africa 15 0/10SA1 0/10SA1 D D

Tanzania 10 D D D D

Uganda 15 D D D D

Zambia 0/20ZA1 D D D D

Zimbabwe 0 D D D D

Bahrain N/ABA1 0 0 D D

Iraq 15 D D D D

Jordan 10 15 15 D D

Oman 10 D D D D

Pakistan 10 D D D D

Qatar 5 0 0 D D

United Arab Emirates (Incl. DIFC) N/AUAE1 0 0 D D

Germany 0/25DE1 0/10DE3 0/10DE3 D D

United Kingdom 0/20GB1 7 7 D D

D - No treaty available. Domestic rates apply. | N/A - Country does not apply withholding tax.

Asia

Afric

aEu

rope

Mid

dle E

ast

Int

er

es

tIntereSt | DIvIDenDS | royAltIeS Africa | A 5

AN1 Interest paid to non-resident companies are subject to withholding tax at a rate of 15%. However, certain interest, such as interest on shareholders loans and bank deposits, are subject to a 10% rate.

BA1 Interest payments are not subject to WHT in Bahrain.

CM1 The standard rate is 15% plus local authority surcharge, making an actual tax of 16.5%.

CN1 A 10% withholding tax applies to interest paid to a non-resident. A 6% VAT also applies to interest payments.

CN3 The 0% rate applies to interest paid to any financial institutions wholly owned by the Government, or to any other resident with respect to debt-claims financed by the Government, a local authority and the Central Bank thereof or any financial institutions wholly owned by the Government.

DE1 Germany generally does not impose withholding tax on interest payments, except for interest on convertible or profit-sharing bonds and over-the-counter transactions where the rate of 25% applies.

DE3 The 0% rate applies to interest paid to a financial institution wholly owned by the Government of the People’s Democratic Republic of Algeria, and interest paid in respect of a loan covered by guarantees of the People’s Democratic Republic of Algeria in relation to exports or foreign direct investment, or if the interest is paid in connection with a sale on credit of industrial, commercial or scientific equipment.

GB1 A 20% WHT is applicable on interest payments to non-residents. However, there are a number of exceptions (e.g. payments of interest that qualify for exemption under the EU interest and Royalties Directive, payments of ‘short’ interest, etc.).

HK1 Hong Kong does not levy withholding tax on interest.

ID1 The 0% rate applies to interest paid to any financial institution controlled by that Government, the capital of which is wholly owned by the Government as may be agreed upon from time to time between the competent authorities of the Contracting States.

IN1 The 20% rate applies with respect to interest on monies borrowed or debts incurred in foreign currency by an Indian concern or the Government. For foreign company, this rate is increased by a surcharge of 2% (when the aggregate income exceeds INR 10 million) or 5% (when the aggregate income exceeds INR 100 million) and is further increased by an education cess of 4% (on income tax and surcharge). A special reduced rate of 5% applies under certain specified circumstances (including interest paid on specific borrowings in foreign currency and interest on investments made by a foreign institutional investor or a qualified foreign investor in a rupee-denominated bond of an Indian company, or in a Government security). In other cases, depending on whether the recipient is a corporate entity, a tax rate of 30% or 40% applies. These tax rates are increased the applicable surcharge and cess.

KE1 Interest paid to banks are exempt from WHT.

KR1 Interest paid to a non-resident generally is subject to a 20% withholding tax, plus the 10% local surtax, bringing the effective rate to 22%.

KR3 The 0% rate applies to interest paid to any financial institution performing functions of a governmental nature.

MU1 The general rate of withholding on interest is 15%, although a 0% rate applies to interest specifically exempted.

MY1 A withholding tax of 15% applies to interest paid to a non-resident, unless the rate is reduced under a tax treaty. However, interest paid to a non-resident by a bank operating in Malaysia is exempt from tax, except for interest accruing to the non-resident’s place of business in Malaysia and interest paid on funds required to maintain “net working funds,” as prescribed by the central bank. Certain other interest paid to a non-resident also may be exempt.

PN1 Generally, interest paid to non-resident foreign corporation is subject to 30% final withholding tax. For interest paid on foreign loans, the tax rate shall be 20% final withholding tax.

SA1 The 0% rate applies on interest paid to financial institutions wholly owned by Algeria, or in relation to loans made in application of an agreement concluded between Algeria and South Africa.

SG1 Interest paid to a non-resident is subject to a 15% withholding tax, unless the rate is reduced under a tax treaty or an exemption applies under certain domestic concessions. The 15% withholding tax is a final tax and applies only to interest not derived by the non-resident from a business carried on in Singapore and not effectively connected to a permanent establishment (PE) in Singapore. Any other interest that does not qualify for the final rate will be taxed at the prevailing corporate tax rate.

TH1 Interest paid to a non-resident company is subject to a 15% withholding tax, unless the rate is reduced under a tax treaty. Interest paid on loans from a bank, financial institution or an insurance company is subject to a 10% withholding tax rate if the lender is resident in a country that has concluded a tax treaty with Thailand, but an exemption applies if the interest is paid by the Government or a Thai financial institution on loans granted under a law intended to promote agriculture, industry or commerce.

TW1 A 15% withholding tax applies to interest paid to a non-resident on short-term bills; interest on securitised certificates; interest on corporate bonds, Government bonds or financial debentures; and interest derived from repurchase transactions for these bonds or certificates.

UAE1 UAE does not impose withholding tax on interest payments.

ZA1 0% withholding tax applies if paid by a mining company.

Double Taxation Treaty Handbook For Corporate Withholding Tax

Domestic Rate (%) Treaty Rate (%)

To › Botswana Cameroon

from Corp - Corp Corp - Bank Corp - Corp Corp - Bank

Australia 10 D D D D

Bangladesh 20 D D D D

Brunei 2.5 D D D D

Cambodia 14 D D D D

China 10CN1 D D D D

Hong Kong 0HK1 D D D D

India 5/20/30/40IN1 10 0/10IN6 D D

Indonesia 20 D D D D

South Korea 20KR1 D D D D

Macau N/A D D D D

Malaysia (Incl. Labuan) 0/15MY1 D D D D

Philippines 20/30PN1 D D D D

Singapore 0/15SG1 D D D D

Sri Lanka 14 D D D D

Taiwan 15/20TW1 D D D D

Thailand 0/10/15TH1 D D D D

Vietnam 5 D D D D

Angola 10/15AN1 D D D D

Botswana 15 D D

Cameroon 16.5CM1 D D

Gambia 15 D D D D

Ghana 8 D D D D

Ivory Coast 18 D D D D

Kenya 0/15KE1 D D D D

Mauritius 0/15MU1 12 0/12MU4 D D

Nigeria 10 D D D D

Sierra Leone 15 D D D D

South Africa 15 10 10 10 10

Tanzania 10 D D D D

Uganda 15 D D D D

Zambia 0/20ZA1 D D D D

Zimbabwe 0 0/10ZI1 0/10ZI1 D D

Bahrain N/ABA1 D D D D

Iraq 15 D D D D

Jordan 10 D D D D

Oman 10 D D D D

Pakistan 10 D D D D

Qatar 5 D D D D

United Arab Emirates (Incl. DIFC) N/AUAE1 D D D D

Germany 0/25DE1 D D D D

United Kingdom 0/20GB1 10 10 D D

D - No treaty available. Domestic rates apply. | N/A - Country does not apply withholding tax.

Asia

Afric

aEu

rope

Mid

dle E

ast

Int

er

es

tIntereSt | DIvIDenDS | royAltIeS Africa | A 7

AN1 Interest paid to non-resident companies are subject to withholding tax at a rate of 15%. However, certain interest, such as interest on shareholders loans and bank deposits, are subject to a 10% rate.

BA1 Interest payments are not subject to WHT in Bahrain.

CM1 The standard rate is 15% plus local authority surcharge, making an actual tax of 16.5%.

CN1 A 10% withholding tax applies to interest paid to a non-resident. A 6% VAT also applies to interest payments.

DE1 Germany generally does not impose withholding tax on interest payments, except for interest on convertible or profit-sharing bonds and over-the-counter transactions where the rate of 25% applies.

GB1 A 20% WHT is applicable on interest payments to non-residents. However, there are a number of exceptions (e.g. payments of interest that qualify for exemption under the EU interest and Royalties Directive, payments of ‘short’ interest, etc.).

HK1 Hong Kong does not levy withholding tax on interest.

IN1 The 20% rate applies with respect to interest on monies borrowed or debts incurred in foreign currency by an Indian concern or the Government. For foreign company, this rate is increased by a surcharge of 2% (when the aggregate income exceeds INR 10 million) or 5% (when the aggregate income exceeds INR 100 million) and is further increased by an education cess of 4% (on income tax and surcharge). A special reduced rate of 5% applies under certain specified circumstances (including interest paid on specific borrowings in foreign currency and interest on investments made by a foreign institutional investor or a qualified foreign investor in a rupee-denominated bond of an Indian company, or in a Government security). In other cases, depending on whether the recipient is a corporate entity, a tax rate of 30% or 40% applies. These tax rates are increased the applicable surcharge and cess.

IN6 The 0% rate applies to interest paid to any other bank or governmental financial institutions or agencies that may be mutually agreed upon between the two Contracting States.

KE1 Interest paid to banks are exempt from WHT.

KR1 Interest paid to a non-resident generally is subject to a 20% withholding tax, plus the 10% local surtax, bringing the effective rate to 22%.

MU1 The general rate of withholding on interest is 15%, although a 0% rate applies to interest specifically exempted.

MU4 The 0% rate applies to interest in respect of a loan granted or guaranteed by a financial institution of a public character with the objective of promoting exports and development, if the loan granted or guaranteed contains an element of subsidy.

MY1 A withholding tax of 15% applies to interest paid to a non-resident, unless the rate is reduced under a tax treaty. However, interest paid to a non-resident by a bank operating in Malaysia is exempt from tax, except for interest accruing to the non-resident’s place of business in Malaysia and interest paid on funds required to maintain “net working funds,” as prescribed by the central bank. Certain other interest paid to a non-resident also may be exempt.

PN1 Generally, interest paid to non-resident foreign corporation is subject to 30% final withholding tax. For interest paid on foreign loans, the tax rate shall be 20% final withholding tax.

SG1 Interest paid to a non-resident is subject to a 15% withholding tax, unless the rate is reduced under a tax treaty or an exemption applies under certain domestic concessions. The 15% withholding tax is a final tax and applies only to interest not derived by the non-resident from a business carried on in Singapore and not effectively connected to a permanent establishment (PE) in Singapore. Any other interest that does not qualify for the final rate will be taxed at the prevailing corporate tax rate.

TH1 Interest paid to a non-resident company is subject to a 15% withholding tax, unless the rate is reduced under a tax treaty. Interest paid on loans from a bank, financial institution or an insurance company is subject to a 10% withholding tax rate if the lender is resident in a country that has concluded a tax treaty with Thailand, but an exemption applies if the interest is paid by the Government or a Thai financial institution on loans granted under a law intended to promote agriculture, industry or commerce.

TW1 A 15% withholding tax applies to interest paid to a non-resident on short-term bills; interest on securitised certificates; interest on corporate bonds, Government bonds or financial debentures; and interest derived from repurchase transactions for these bonds or certificates.

UAE1 UAE does not impose withholding tax on interest payments.

ZA1 0% withholding tax applies if paid by a mining company.

ZI1 The 0% rate applies to interest paid in respect of a loan granted or guaranteed by a financial institution of a public character with the objective of promoting exports and development, if the credit granted or guaranteed contains an element of subsidy.

Double Taxation Treaty Handbook For Corporate Withholding Tax

Domestic Rate (%) Treaty Rate (%)

To › Cape Verde Congo

from Corp - Corp Corp - Bank Corp - Corp Corp - Bank

Australia 10 D D D D

Bangladesh 20 D D D D

Brunei 2.5 D D D D

Cambodia 14 D D D D

China 10CN1 D D D D

Hong Kong 0HK1 D D D D

India 5/20/30/40IN1 D D D D

Indonesia 20 D D D D

South Korea 20KR1 D D D D

Macau N/A 10 10 D D

Malaysia (Incl. Labuan) 0/15MY1 D D D D

Philippines 20/30PN1 D D D D

Singapore 0/15SG1 D D D D

Sri Lanka 14 D D D D

Taiwan 15/20TW1 D D D D

Thailand 0/10/15TH1 D D D D

Vietnam 5 D D D D

Angola 10/15AN1 D D D D

Botswana 15 D D D D

Cameroon 16.5CM1 D D D D

Gambia 15 D D D D

Ghana 8 D D D D

Ivory Coast 18 D D D D

Kenya 0/15KE1 D D D D

Mauritius 0/15MU1 D D 5 5

Nigeria 10 D D D D

Sierra Leone 15 D D D D

South Africa 15 D D 10 10

Tanzania 10 D D D D

Uganda 15 D D D D

Zambia 0/20ZA1 D D D D

Zimbabwe 0 D D D D

Bahrain N/ABA1 D D D D

Iraq 15 D D D D

Jordan 10 D D D D

Oman 10 D D D D

Pakistan 10 D D D D

Qatar 5 D D D D

United Arab Emirates (Incl. DIFC) N/AUAE1 D D D D

Germany 0/25DE1 D D D D

United Kingdom 0/20GB1 D D D D

D - No treaty available. Domestic rates apply. | N/A - Country does not apply withholding tax.

Asia

Afric

aEu

rope

Mid

dle E

ast

Int

er

es

tIntereSt | DIvIDenDS | royAltIeS Africa | A 9

AN1 Interest paid to non-resident companies are subject to withholding tax at a rate of 15%. However, certain interest, such as interest on shareholders loans and bank deposits, are subject to a 10% rate.

BA1 Interest payments are not subject to WHT in Bahrain.

CM1 The standard rate is 15% plus local authority surcharge, making an actual tax of 16.5%.

CN1 A 10% withholding tax applies to interest paid to a non-resident. A 6% VAT also applies to interest payments.

DE1 Germany generally does not impose withholding tax on interest payments, except for interest on convertible or profit-sharing bonds and over-the-counter transactions where the rate of 25% applies.

GB1 A 20% WHT is applicable on interest payments to non-residents. However, there are a number of exceptions (e.g. payments of interest that qualify for exemption under the EU interest and Royalties Directive, payments of ‘short’ interest, etc.).

HK1 Hong Kong does not levy withholding tax on interest.

IN1 The 20% rate applies with respect to interest on monies borrowed or debts incurred in foreign currency by an Indian concern or the Government. For foreign company, this rate is increased by a surcharge of 2% (when the aggregate income exceeds INR 10 million) or 5% (when the aggregate income exceeds INR 100 million) and is further increased by an education cess of 4% (on income tax and surcharge). A special reduced rate of 5% applies under certain specified circumstances (including interest paid on specific borrowings in foreign currency and interest on investments made by a foreign institutional investor or a qualified foreign investor in a rupee-denominated bond of an Indian company, or in a Government security). In other cases, depending on whether the recipient is a corporate entity, a tax rate of 30% or 40% applies. These tax rates are increased the applicable surcharge and cess.

KE1 Interest paid to banks are exempt from WHT.

KR1 Interest paid to a non-resident generally is subject to a 20% withholding tax, plus the 10% local surtax, bringing the effective rate to 22%.

MU1 The general rate of withholding on interest is 15%, although a 0% rate applies to interest specifically exempted.

MY1 A withholding tax of 15% applies to interest paid to a non-resident, unless the rate is reduced under a tax treaty. However, interest paid to a non-resident by a bank operating in Malaysia is exempt from tax, except for interest accruing to the non-resident’s place of business in Malaysia and interest paid on funds required to maintain “net working funds,” as prescribed by the central bank. Certain other interest paid to a non-resident also may be exempt.

PN1 Generally, interest paid to non-resident foreign corporation is subject to 30% final withholding tax. For interest paid on foreign loans, the tax rate shall be 20% final withholding tax.

SG1 Interest paid to a non-resident is subject to a 15% withholding tax, unless the rate is reduced under a tax treaty or an exemption applies under certain domestic concessions. The 15% withholding tax is a final tax and applies only to interest not derived by the non-resident from a business carried on in Singapore and not effectively connected to a permanent establishment (PE) in Singapore. Any other interest that does not qualify for the final rate will be taxed at the prevailing corporate tax rate.

TH1 Interest paid to a non-resident company is subject to a 15% withholding tax, unless the rate is reduced under a tax treaty. Interest paid on loans from a bank, financial institution or an insurance company is subject to a 10% withholding tax rate if the lender is resident in a country that has concluded a tax treaty with Thailand, but an exemption applies if the interest is paid by the Government or a Thai financial institution on loans granted under a law intended to promote agriculture, industry or commerce.

TW1 A 15% withholding tax applies to interest paid to a non-resident on short-term bills; interest on securitised certificates; interest on corporate bonds, Government bonds or financial debentures; and interest derived from repurchase transactions for these bonds or certificates.

UAE1 UAE does not impose withholding tax on interest payments.

ZA1 0% withholding tax applies if paid by a mining company.

Double Taxation Treaty Handbook For Corporate Withholding Tax

Domestic Rate (%) Treaty Rate (%)

To › Egypt

from Corp - Corp Corp - Bank

Australia 10 D D

Bangladesh 20 D D

Brunei 2.5 D D

Cambodia 14 D D

China 10CN1 10 10

Hong Kong 0HK1 D D

India 5/20/30/40IN1 D D

Indonesia 20 15 0/15ID1

South Korea 20KR1 0/10/15KR18 0/10/15KR18

Macau N/A D D

Malaysia (Incl. Labuan) 0/15MY1 0/15MY8 0/15MY8

Philippines 20/30PN1 D D

Singapore 0/15SG1 15 15

Sri Lanka 14 D D

Taiwan 15/20TW1 D D

Thailand 0/10/15TH1 D D

Vietnam 5 D D

Angola 10/15AN1 D D

Botswana 15 D D

Cameroon 16.5CM1 D D

Gambia 15 D D

Ghana 8 D D

Ivory Coast 18 D D

Kenya 0/15KE1 D D

Mauritius 0/15MU1 10 10

Nigeria 10 D D

Sierra Leone 15 D D

South Africa 15 12 12

Tanzania 10 D D

Uganda 15 D D

Zambia 0/20ZA1 D D

Zimbabwe 0 D D

Bahrain N/ABA1 10 10

Iraq 15 D D

Jordan 10 15 15

Oman 10 D D

Pakistan 10 0/15PK11 0/15PK11

Qatar 5 D D

United Arab Emirates (Incl. DIFC) N/AUAE1 10 10

Germany 0/25DE1 0/15DE14 0/15DE14

United Kingdom 0/20GB1 15 15

D - No treaty available. Domestic rates apply. | N/A - Country does not apply withholding tax.

Asia

Afric

aEu

rope

Mid

dle E

ast

Int

er

es

tIntereSt | DIvIDenDS | royAltIeS Africa | A 11

AN1 Interest paid to non-resident companies are subject to withholding tax at a rate of 15%. However, certain interest, such as interest on shareholders loans and bank deposits, are subject to a 10% rate.

BA1 Interest payments are not subject to WHT in Bahrain.

CM1 The standard rate is 15% plus local authority surcharge, making an actual tax of 16.5%.

CN1 A 10% withholding tax applies to interest paid to a non-resident. A 6% VAT also applies to interest payments.

DE1 Germany generally does not impose withholding tax on interest payments, except for interest on convertible or profit-sharing bonds and over-the-counter transactions where the rate of 25% applies.

DE14 The 0% rate applies to interest paid on loans guaranteed, or insured by Egypt.

GB1 A 20% WHT is applicable on interest payments to non-residents. However, there are a number of exceptions (e.g. payments of interest that qualify for exemption under the EU interest and Royalties Directive, payments of ‘short’ interest, etc.).

HK1 Hong Kong does not levy withholding tax on interest.

ID1 The 0% rate applies to interest paid to any financial institution controlled by that Government, the capital of which is wholly owned by the Government as may be agreed upon from time to time between the competent authorities of the Contracting States.

IN1 The 20% rate applies with respect to interest on monies borrowed or debts incurred in foreign currency by an Indian concern or the Government. For foreign company, this rate is increased by a surcharge of 2% (when the aggregate income exceeds INR 10 million) or 5% (when the aggregate income exceeds INR 100 million) and is further increased by an education cess of 4% (on income tax and surcharge). A special reduced rate of 5% applies under certain specified circumstances (including interest paid on specific borrowings in foreign currency and interest on investments made by a foreign institutional investor or a qualified foreign investor in a rupee-denominated bond of an Indian company, or in a Government security). In other cases, depending on whether the recipient is a corporate entity, a tax rate of 30% or 40% applies. These tax rates are increased the applicable surcharge and cess.

KE1 Interest paid to banks are exempt from WHT.

KR1 Interest paid to a non-resident generally is subject to a 20% withholding tax, plus the 10% local surtax, bringing the effective rate to 22%.

KR18 The 0% rate applies to interest paid in respect of loans or credits made or guaranteed, (a) in the case of Korea, by the Export Import Bank of Korea; (b) in the case of Egypt, by the Bank equivalent to the Export Import Bank of Korea; and paid to a resident.

The 10% rate applies to loans for a period exceeding three years.

MU1 The general rate of withholding on interest is 15%, although a 0% rate applies to interest specifically exempted.

MY1 A withholding tax of 15% applies to interest paid to a non-resident, unless the rate is reduced under a tax treaty. However, interest paid to a non-resident by a bank operating in Malaysia is exempt from tax, except for interest accruing to the non-resident’s place of business in Malaysia and interest paid on funds required to maintain “net working funds,” as prescribed by the central bank. Certain other interest paid to a non-resident also may be exempt.

MY8 The 0% rate applies to interest paid to companies or institutions wholly owned by the Government of Malaysia or if the loan or other indebtedness in respect of which the interest is paid is an approved loan as defined under Malaysian Law.

PK11 The 0% rate applies to interest paid to a local authority thereof or any agency or instrumentality of that State subject to the agreement of the competent authorities.

PN1 Generally, interest paid to non-resident foreign corporation is subject to 30% final withholding tax. For interest paid on foreign loans, the tax rate shall be 20% final withholding tax.

SG1 Interest paid to a non-resident is subject to a 15% withholding tax, unless the rate is reduced under a tax treaty or an exemption applies under certain domestic concessions. The 15% withholding tax is a final tax and applies only to interest not derived by the non-resident from a business carried on in Singapore and not effectively connected to a permanent establishment (PE) in Singapore. Any other interest that does not qualify for the final rate will be taxed at the prevailing corporate tax rate.

TH1 Interest paid to a non-resident company is subject to a 15% withholding tax, unless the rate is reduced under a tax treaty. Interest paid on loans from a bank, financial institution or an insurance company is subject to a 10% withholding tax rate if the lender is resident in a country that has concluded a tax treaty with Thailand, but an exemption applies if the interest is paid by the Government or a Thai financial institution on loans granted under a law intended to promote agriculture, industry or commerce.

TW1 A 15% withholding tax applies to interest paid to a non-resident on short-term bills; interest on securitised certificates; interest on corporate bonds, Government bonds or financial debentures; and interest derived from repurchase transactions for these bonds or certificates.

UAE1 UAE does not impose withholding tax on interest payments.

ZA1 0% withholding tax applies if paid by a mining company.

Double Taxation Treaty Handbook For Corporate Withholding Tax

Domestic Rate (%) Treaty Rate (%)

To › Ethiopia Gabon

from Corp - Corp Corp - Bank Corp - Corp Corp - Bank

Australia 10 D D D D

Bangladesh 20 D D D D

Brunei 2.5 D D D D

Cambodia 14 D D D D

China 10CN1 0/7CN18 0/7CN18 D D

Hong Kong 0HK1 D D D D

India 5/20/30/40IN1 0/10IN2 0/10IN2 D D

Indonesia 20 D D D D

South Korea 20KR1 0/7.5KR20 0/7.5KR20 0/10KR23 0/10KR23

Macau N/A D D D D

Malaysia (Incl. Labuan) 0/15MY1 D D D D

Philippines 20/30PN1 D D D D

Singapore 0/15SG1 5 5 D D

Sri Lanka 14 D D D D

Taiwan 15/20TW1 D D D D

Thailand 0/10/15TH1 D D D D

Vietnam 5 D D D D

Angola 10/15AN1 D D D D

Botswana 15 D D D D

Cameroon 16.5CM1 D D D D

Gambia 15 D D D D

Ghana 8 D D D D

Ivory Coast 18 D D D D

Kenya 0/15KE1 D D D D

Mauritius 0/15MU1 D D D D

Nigeria 10 D D D D

Sierra Leone 15 D D D D

South Africa 15 8 8 D D

Tanzania 10 D D D D

Uganda 15 D D D D

Zambia 0/20ZA1 D D D D

Zimbabwe 0 D D D D

Bahrain N/ABA1 D D D D

Iraq 15 D D D D

Jordan 10 D D D D

Oman 10 D D D D

Pakistan 10 D D D D

Qatar 5 D D D D

United Arab Emirates (Incl. DIFC) N/AUAE1 D D D D

Germany 0/25DE1 D D D D

United Kingdom 0/20GB1 5 5 D D

D - No treaty available. Domestic rates apply. | N/A - Country does not apply withholding tax.

Asia

Afric

aEu

rope

Mid

dle E

ast

Int

er

es

tIntereSt | DIvIDenDS | royAltIeS Africa | A 13

AN1 Interest paid to non-resident companies are subject to withholding tax at a rate of 15%. However, certain interest, such as interest on shareholders loans and bank deposits, are subject to a 10% rate.

BA1 Interest payments are not subject to WHT in Bahrain.

CM1 The standard rate is 15% plus local authority surcharge, making an actual tax of 16.5%.

CN1 A 10% withholding tax applies to interest paid to a non-resident. A 6% VAT also applies to interest payments.

CN18 The 0% rate applies to interest paid on loans guaranteed or insured by the Government, a local authority or the Central Bank.

DE1 Germany generally does not impose withholding tax on interest payments, except for interest on convertible or profit-sharing bonds and over-the-counter transactions where the rate of 25% applies.

GB1 A 20% WHT is applicable on interest payments to non-residents. However, there are a number of exceptions (e.g. payments of interest that qualify for exemption under the EU interest and Royalties Directive, payments of ‘short’ interest, etc.).

HK1 Hong Kong does not levy withholding tax on interest.

IN1 The 20% rate applies with respect to interest on monies borrowed or debts incurred in foreign currency by an Indian concern or the Government. For foreign company, this rate is increased by a surcharge of 2% (when the aggregate income exceeds INR 10 million) or 5% (when the aggregate income exceeds INR 100 million) and is further increased by an education cess of 4% (on income tax and surcharge). A special reduced rate of 5% applies under certain specified circumstances (including interest paid on specific borrowings in foreign currency and interest on investments made by a foreign institutional investor or a qualified foreign investor in a rupee-denominated bond of an Indian company, or in a Government security). In other cases, depending on whether the recipient is a corporate entity, a tax rate of 30% or 40% applies. These tax rates are increased the applicable surcharge and cess.

IN2 The 0% rate applies to interest paid to any other institution as may be agreed upon from time to time between the competent authorities of the Contracting States through exchange of letters.

KE1 Interest paid to banks are exempt from WHT.

KR1 Interest paid to a non-resident generally is subject to a 20% withholding tax, plus the 10% local surtax, bringing the effective rate to 22%.

KR20 The 0% rate applies if (a) the interest is paid in respect of a loan, debt-claim or credit that is guaranteed or insured by either Contracting State or a political subdivision, or a local authority thereof; (b) the interest is paid in respect of a loan made, guaranteed or insured by an export financing institution owned by that State, provided that the loan is given to the Government of Korea.

KR23 The 0% rate applies to interest paid (a) in connection with the credit sale of industrial, commercial or scientific equipment or the credit sale of merchandise by one enterprise to another enterprise; or (b) to any financial institution performing functions of a governmental nature.

MU1 The general rate of withholding on interest is 15%, although a 0% rate applies to interest specifically exempted.

MY1 A withholding tax of 15% applies to interest paid to a non-resident, unless the rate is reduced under a tax treaty. However, interest paid to a non-resident by a bank operating in Malaysia is exempt from tax, except for interest accruing to the non-resident’s place of business in Malaysia and interest paid on funds required to maintain “net working funds,” as prescribed by the central bank. Certain other interest paid to a non-resident also may be exempt.

PN1 Generally, interest paid to non-resident foreign corporation is subject to 30% final withholding tax. For interest paid on foreign loans, the tax rate shall be 20% final withholding tax.

SG1 Interest paid to a non-resident is subject to a 15% withholding tax, unless the rate is reduced under a tax treaty or an exemption applies under certain domestic concessions. The 15% withholding tax is a final tax and applies only to interest not derived by the non-resident from a business carried on in Singapore and not effectively connected to a permanent establishment (PE) in Singapore. Any other interest that does not qualify for the final rate will be taxed at the prevailing corporate tax rate.

TH1 Interest paid to a non-resident company is subject to a 15% withholding tax, unless the rate is reduced under a tax treaty. Interest paid on loans from a bank, financial institution or an insurance company is subject to a 10% withholding tax rate if the lender is resident in a country that has concluded a tax treaty with Thailand, but an exemption applies if the interest is paid by the Government or a Thai financial institution on loans granted under a law intended to promote agriculture, industry or commerce.

TW1 A 15% withholding tax applies to interest paid to a non-resident on short-term bills; interest on securitised certificates; interest on corporate bonds, Government bonds or financial debentures; and interest derived from repurchase transactions for these bonds or certificates.

UAE1 UAE does not impose withholding tax on interest payments.

ZA1 0% withholding tax applies if paid by a mining company.

Double Taxation Treaty Handbook For Corporate Withholding Tax

Domestic Rate (%) Treaty Rate (%)

To › Gambia Ghana

from Corp - Corp Corp - Bank Corp - Corp Corp - Bank

Australia 10 D D D D

Bangladesh 20 D D D D

Brunei 2.5 D D D D

Cambodia 14 D D D D

China 10CN1 D D D D

Hong Kong 0HK1 D D D D

India 5/20/30/40IN1 D D D D

Indonesia 20 D D D D

South Korea 20KR1 D D D D

Macau N/A D D D D

Malaysia (Incl. Labuan) 0/15MY1 D D D D

Philippines 20/30PN1 D D D D

Singapore 0/15SG1 D D D D

Sri Lanka 14 D D D D

Taiwan 15/20TW1 0/10TW7 0/10TW7 D D

Thailand 0/10/15TH1 D D D D

Vietnam 5 D D D D

Angola 10/15AN1 D D D D

Botswana 15 D D D D

Cameroon 16.5CM1 D D D D

Gambia 15 D D

Ghana 8 D D

Ivory Coast 18 D D D D

Kenya 0/15KE1 D D D D

Mauritius 0/15MU1 D D D D

Nigeria 10 D D D D

Sierra Leone 15 D D D D

South Africa 15 D D 10 5

Tanzania 10 D D D D

Uganda 15 D D D D

Zambia 0/20ZA1 D D D D

Zimbabwe 0 D D D D

Bahrain N/ABA1 D D D D

Iraq 15 D D D D

Jordan 10 D D D D

Oman 10 D D D D

Pakistan 10 D D D D

Qatar 5 D D D D

United Arab Emirates (Incl. DIFC) N/AUAE1 D D D D

Germany 0/25DE1 D D 0/10DE16 0

United Kingdom 0/20GB1 15 15 12.5 12.5

D - No treaty available. Domestic rates apply. | N/A - Country does not apply withholding tax.

Asia

Afric

aEu

rope

Mid

dle E

ast

Int

er

es

tIntereSt | DIvIDenDS | royAltIeS Africa | A 15

AN1 Interest paid to non-resident companies are subject to withholding tax at a rate of 15%. However, certain interest, such as interest on shareholders loans and bank deposits, are subject to a 10% rate.

BA1 Interest payments are not subject to WHT in Bahrain.

CM1 The standard rate is 15% plus local authority surcharge, making an actual tax of 16.5%.

CN1 A 10% withholding tax applies to interest paid to a non-resident. A 6% VAT also applies to interest payments.

DE1 Germany generally does not impose withholding tax on interest payments, except for interest on convertible or profit-sharing bonds and over-the-counter transactions where the rate of 25% applies.

DE16 The 0% rate applies to interest paid on on sale on credit of commercial and scientific equipment; sale on credit of merchandise by one enterprise to another.

GB1 A 20% WHT is applicable on interest payments to non-residents. However, there are a number of exceptions (e.g. payments of interest that qualify for exemption under the EU interest and Royalties Directive, payments of ‘short’ interest, etc.).

HK1 Hong Kong does not levy withholding tax on interest.

IN1 The 20% rate applies with respect to interest on monies borrowed or debts incurred in foreign currency by an Indian concern or the Government. For foreign company, this rate is increased by a surcharge of 2% (when the aggregate income exceeds INR 10 million) or 5% (when the aggregate income exceeds INR 100 million) and is further increased by an education cess of 4% (on income tax and surcharge). A special reduced rate of 5% applies under certain specified circumstances (including interest paid on specific borrowings in foreign currency and interest on investments made by a foreign institutional investor or a qualified foreign investor in a rupee-denominated bond of an Indian company, or in a Government security). In other cases, depending on whether the recipient is a corporate entity, a tax rate of 30% or 40% applies. These tax rates are increased the applicable surcharge and cess.

KE1 Interest paid to banks are exempt from WHT.

KR1 Interest paid to a non-resident generally is subject to a 20% withholding tax, plus the 10% local surtax, bringing the effective rate to 22%.

MU1 The general rate of withholding on interest is 15%, although a 0% rate applies to interest specifically exempted.

MY1 A withholding tax of 15% applies to interest paid to a non-resident, unless the rate is reduced under a tax treaty. However, interest paid to a non-resident by a bank operating in Malaysia is exempt from tax, except for interest accruing to the non-resident’s place of business in Malaysia and interest paid on funds required to maintain “net working funds,” as prescribed by the central bank. Certain other interest paid to a non-resident also may be exempt.

PN1 Generally, interest paid to non-resident foreign corporation is subject to 30% final withholding tax. For interest paid on foreign loans, the tax rate shall be 20% final withholding tax.

SG1 Interest paid to a non-resident is subject to a 15% withholding tax, unless the rate is reduced under a tax treaty or an exemption applies under certain domestic concessions. The 15% withholding tax is a final tax and applies only to interest not derived by the non-resident from a business carried on in Singapore and not effectively connected to a permanent establishment (PE) in Singapore. Any other interest that does not qualify for the final rate will be taxed at the prevailing corporate tax rate.

TH1 Interest paid to a non-resident company is subject to a 15% withholding tax, unless the rate is reduced under a tax treaty. Interest paid on loans from a bank, financial institution or an insurance company is subject to a 10% withholding tax rate if the lender is resident in a country that has concluded a tax treaty with Thailand, but an exemption applies if the interest is paid by the Government or a Thai financial institution on loans granted under a law intended to promote agriculture, industry or commerce.

TW1 A 15% withholding tax applies to interest paid to a non-resident on short-term bills; interest on securitised certificates; interest on corporate bonds, Government bonds or financial debentures; and interest derived from repurchase transactions for these bonds or certificates.

TW7 The 0% rate applies if the interest is beneficially owned by a resident with respect to debt obligations guaranteed or insured by Gambia, a political subdivision or local authority thereof or an instrumentality subdivision or authority of Gambia which is not subjected to tax by that Gambia.

UAE1 UAE does not impose withholding tax on interest payments.

ZA1 0% withholding tax applies if paid by a mining company.

Double Taxation Treaty Handbook For Corporate Withholding Tax

Domestic Rate (%) Treaty Rate (%)

To › Guinea Ivory Coast

from Corp - Corp Corp - Bank Corp - Corp Corp - Bank

Australia 10 D D D D

Bangladesh 20 D D D D

Brunei 2.5 D D D D

Cambodia 14 D D D D

China 10CN1 D D D D

Hong Kong 0HK1 D D D D

India 5/20/30/40IN1 D D D D

Indonesia 20 D D D D

South Korea 20KR1 D D D D

Macau N/A D D D D

Malaysia (Incl. Labuan) 0/15MY1 D D D D

Philippines 20/30PN1 D D D D

Singapore 0/15SG1 D D D D

Sri Lanka 14 D D D D

Taiwan 15/20TW1 D D D D

Thailand 0/10/15TH1 D D D D

Vietnam 5 D D D D

Angola 10/15AN1 D D D D

Botswana 15 D D D D

Cameroon 16.5CM1 D D D D

Gambia 15 D D D D

Ghana 8 D D D D

Ivory Coast 18 D D

Kenya 0/15KE1 D D D D

Mauritius 0/15MU1 D D D D

Nigeria 10 D D D D

Sierra Leone 15 D D D D

South Africa 15 D D D D

Tanzania 10 D D D D

Uganda 15 D D D D

Zambia 0/20ZA1 D D D D

Zimbabwe 0 D D D D

Bahrain N/ABA1 D D D D

Iraq 15 D D D D

Jordan 10 D D D D

Oman 10 D D D D

Pakistan 10 D D D D

Qatar 5 D D D D

United Arab Emirates (Incl. DIFC) N/AUAE1 0 0 D D

Germany 0/25DE1 D D 15 15

United Kingdom 0/20GB1 D D 15 15

D - No treaty available. Domestic rates apply. | N/A - Country does not apply withholding tax.

Asia

Afric

aEu

rope

Mid

dle E

ast

Int

er

es

tIntereSt | DIvIDenDS | royAltIeS Africa | A 17

AN1 Interest paid to non-resident companies are subject to withholding tax at a rate of 15%. However, certain interest, such as interest on shareholders loans and bank deposits, are subject to a 10% rate.

BA1 Interest payments are not subject to WHT in Bahrain.

CM1 The standard rate is 15% plus local authority surcharge, making an actual tax of 16.5%.

CN1 A 10% withholding tax applies to interest paid to a non-resident. A 6% VAT also applies to interest payments.

DE1 Germany generally does not impose withholding tax on interest payments, except for interest on convertible or profit-sharing bonds and over-the-counter transactions where the rate of 25% applies.

GB1 A 20% WHT is applicable on interest payments to non-residents. However, there are a number of exceptions (e.g. payments of interest that qualify for exemption under the EU interest and Royalties Directive, payments of ‘short’ interest, etc.).

HK1 Hong Kong does not levy withholding tax on interest.

IN1 The 20% rate applies with respect to interest on monies borrowed or debts incurred in foreign currency by an Indian concern or the Government. For foreign company, this rate is increased by a surcharge of 2% (when the aggregate income exceeds INR 10 million) or 5% (when the aggregate income exceeds INR 100 million) and is further increased by an education cess of 4% (on income tax and surcharge). A special reduced rate of 5% applies under certain specified circumstances (including interest paid on specific borrowings in foreign currency and interest on investments made by a foreign institutional investor or a qualified foreign investor in a rupee-denominated bond of an Indian company, or in a Government security). In other cases, depending on whether the recipient is a corporate entity, a tax rate of 30% or 40% applies. These tax rates are increased the applicable surcharge and cess.

KE1 Interest paid to banks are exempt from WHT.

KR1 Interest paid to a non-resident generally is subject to a 20% withholding tax, plus the 10% local surtax, bringing the effective rate to 22%.

MU1 The general rate of withholding on interest is 15%, although a 0% rate applies to interest specifically exempted.

MY1 A withholding tax of 15% applies to interest paid to a non-resident, unless the rate is reduced under a tax treaty. However, interest paid to a non-resident by a bank operating in Malaysia is exempt from tax, except for interest accruing to the non-resident’s place of business in Malaysia and interest paid on funds required to maintain “net working funds,” as prescribed by the central bank. Certain other interest paid to a non-resident also may be exempt.

PN1 Generally, interest paid to non-resident foreign corporation is subject to 30% final withholding tax. For interest paid on foreign loans, the tax rate shall be 20% final withholding tax.

SG1 Interest paid to a non-resident is subject to a 15% withholding tax, unless the rate is reduced under a tax treaty or an exemption applies under certain domestic concessions. The 15% withholding tax is a final tax and applies only to interest not derived by the non-resident from a business carried on in Singapore and not effectively connected to a permanent establishment (PE) in Singapore. Any other interest that does not qualify for the final rate will be taxed at the prevailing corporate tax rate.

TH1 Interest paid to a non-resident company is subject to a 15% withholding tax, unless the rate is reduced under a tax treaty. Interest paid on loans from a bank, financial institution or an insurance company is subject to a 10% withholding tax rate if the lender is resident in a country that has concluded a tax treaty with Thailand, but an exemption applies if the interest is paid by the Government or a Thai financial institution on loans granted under a law intended to promote agriculture, industry or commerce.

TW1 A 15% withholding tax applies to interest paid to a non-resident on short-term bills; interest on securitised certificates; interest on corporate bonds, Government bonds or financial debentures; and interest derived from repurchase transactions for these bonds or certificates.

UAE1 UAE does not impose withholding tax on interest payments.

ZA1 0% withholding tax applies if paid by a mining company.

Double Taxation Treaty Handbook For Corporate Withholding Tax

Domestic Rate (%) Treaty Rate (%)

To › Kenya Lesotho

from Corp - Corp Corp - Bank Corp - Corp Corp - Bank

Australia 10 D D D D

Bangladesh 20 D D D D

Brunei 2.5 D D D D

Cambodia 14 D D D D

China 10CN1 D D D D

Hong Kong 0HK1 D D D D

India 5/20/30/40IN1 10 0/10IN21 D D

Indonesia 20 D D D D

South Korea 20KR1 0/12KR35 0/12KR35 D D

Macau N/A D D D D

Malaysia (Incl. Labuan) 0/15MY1 D D D D

Philippines 20/30PN1 D D D D

Singapore 0/15SG1 D D D D

Sri Lanka 14 D D D D

Taiwan 15/20TW1 D D D D

Thailand 0/10/15TH1 D D D D

Vietnam 5 D D D D

Angola 10/15AN1 D D D D

Botswana 15 D D D D

Cameroon 16.5CM1 D D D D

Gambia 15 D D D D

Ghana 8 D D D D

Ivory Coast 18 D D D D

Kenya 0/15KE1 D D

Mauritius 0/15MU1 D D 10 10

Nigeria 10 D D D D

Sierra Leone 15 D D D D

South Africa 15 10 10 10 10

Tanzania 10 D D D D

Uganda 15 D D D D

Zambia 0/20ZA1 0/DZA6 0/DZA6 D D

Zimbabwe 0 D D D D

Bahrain N/ABA1 D D D D

Iraq 15 D D D D

Jordan 10 D D D D

Oman 10 D D D D

Pakistan 10 D D D D

Qatar 5 D D D D

United Arab Emirates (Incl. DIFC) N/AUAE1 10 0/10UAE8 D D

Germany 0/25DE1 15 15 D D

United Kingdom 0/20GB1 15 15 10 10

D - No treaty available. Domestic rates apply. | N/A - Country does not apply withholding tax.

Asia

Afric

aEu

rope

Mid

dle E

ast

Int

er

es

tIntereSt | DIvIDenDS | royAltIeS Africa | A 19

AN1 Interest paid to non-resident companies are subject to withholding tax at a rate of 15%. However, certain interest, such as interest on shareholders loans and bank deposits, are subject to a 10% rate.

BA1 Interest payments are not subject to WHT in Bahrain.

CM1 The standard rate is 15% plus local authority surcharge, making an actual tax of 16.5%.

CN1 A 10% withholding tax applies to interest paid to a non-resident. A 6% VAT also applies to interest payments.

DE1 Germany generally does not impose withholding tax on interest payments, except for interest on convertible or profit-sharing bonds and over-the-counter transactions where the rate of 25% applies.

GB1 A 20% WHT is applicable on interest payments to non-residents. However, there are a number of exceptions (e.g. payments of interest that qualify for exemption under the EU interest and Royalties Directive, payments of ‘short’ interest, etc.).

HK1 Hong Kong does not levy withholding tax on interest.

IN1 The 20% rate applies with respect to interest on monies borrowed or debts incurred in foreign currency by an Indian concern or the Government. For foreign company, this rate is increased by a surcharge of 2% (when the aggregate income exceeds INR 10 million) or 5% (when the aggregate income exceeds INR 100 million) and is further increased by an education cess of 4% (on income tax and surcharge). A special reduced rate of 5% applies under certain specified circumstances (including interest paid on specific borrowings in foreign currency and interest on investments made by a foreign institutional investor or a qualified foreign investor in a rupee-denominated bond of an Indian company, or in a Government security). In other cases, depending on whether the recipient is a corporate entity, a tax rate of 30% or 40% applies. These tax rates are increased the applicable surcharge and cess.

IN21 The 0% rate applies to interest paid to any other Government financial institution / entity as may be agreed upon from time to time between the Competent authorities of the Contracting States through exchange of letters.

KE1 Interest paid to banks are exempt from WHT.

KR1 Interest paid to a non-resident generally is subject to a 20% withholding tax, plus the 10% local surtax, bringing the effective rate to 22%.

KR35 The 0% rate applies interest paid to, or paid in respect of a loan or credit owed to, or made or guaranteed by (a) the Government, a political subdivision, a local authority or the Central Bank; or (b) any institution which is wholly owned by the Government, a political subdivision, a local authority or the Central Bank.

MU1 The general rate of withholding on interest is 15%, although a 0% rate applies to interest specifically exempted.

MY1 A withholding tax of 15% applies to interest paid to a non-resident, unless the rate is reduced under a tax treaty. However, interest paid to a non-resident by a bank operating in Malaysia is exempt from tax, except for interest accruing to the non-resident’s place of business in Malaysia and interest paid on funds required to maintain “net working funds,” as prescribed by the central bank. Certain other interest paid to a non-resident also may be exempt.

PN1 Generally, interest paid to non-resident foreign corporation is subject to 30% final withholding tax. For interest paid on foreign loans, the tax rate shall be 20% final withholding tax.

SG1 Interest paid to a non-resident is subject to a 15% withholding tax, unless the rate is reduced under a tax treaty or an exemption applies under certain domestic concessions. The 15% withholding tax is a final tax and applies only to interest not derived by the non-resident from a business carried on in Singapore and not effectively connected to a permanent establishment (PE) in Singapore. Any other interest that does not qualify for the final rate will be taxed at the prevailing corporate tax rate.

TH1 Interest paid to a non-resident company is subject to a 15% withholding tax, unless the rate is reduced under a tax treaty. Interest paid on loans from a bank, financial institution or an insurance company is subject to a 10% withholding tax rate if the lender is resident in a country that has concluded a tax treaty with Thailand, but an exemption applies if the interest is paid by the Government or a Thai financial institution on loans granted under a law intended to promote agriculture, industry or commerce.

TW1 A 15% withholding tax applies to interest paid to a non-resident on short-term bills; interest on securitised certificates; interest on corporate bonds, Government bonds or financial debentures; and interest derived from repurchase transactions for these bonds or certificates.

UAE1 UAE does not impose withholding tax on interest payments.

UAE8 The 0% rate applies to interest paid to financial institutions as may be specified and agreed between UAE and Kenya.

ZA1 0% withholding tax applies if paid by a mining company.

ZA6 The domestic rate applies if income is exempt from tax in the recipient country.

Double Taxation Treaty Handbook For Corporate Withholding Tax

Domestic Rate (%) Treaty Rate (%)

To › Liberia Libya

from Corp - Corp Corp - Bank Corp - Corp Corp - Bank

Australia 10 D D D D

Bangladesh 20 D D D D

Brunei 2.5 D D D D

Cambodia 14 D D D D

China 10CN1 D D D D

Hong Kong 0HK1 D D D D

India 5/20/30/40IN1 D D D D

Indonesia 20 D D D D

South Korea 20KR1 D D D D

Macau N/A D D D D

Malaysia (Incl. Labuan) 0/15MY1 D D D D

Philippines 20/30PN1 D D D D

Singapore 0/15SG1 D D 0/5SG35 0/5SG35

Sri Lanka 14 D D D D

Taiwan 15/20TW1 D D D D

Thailand 0/10/15TH1 D D D D

Vietnam 5 D D D D

Angola 10/15AN1 D D D D

Botswana 15 D D D D

Cameroon 16.5CM1 D D D D

Gambia 15 D D D D

Ghana 8 D D D D

Ivory Coast 18 D D D D

Kenya 0/15KE1 D D D D

Mauritius 0/15MU1 D D D D

Nigeria 10 D D D D

Sierra Leone 15 D D D D

South Africa 15 D D D D

Tanzania 10 D D D D

Uganda 15 D D D D

Zambia 0/20ZA1 D D D D

Zimbabwe 0 D D D D

Bahrain N/ABA1 D D D D

Iraq 15 D D D D

Jordan 10 D D D D

Oman 10 D D D D

Pakistan 10 D D D D

Qatar 5 D D D D

United Arab Emirates (Incl. DIFC) N/AUAE1 D D D D

Germany 0/25DE1 20 10 D D

United Kingdom 0/20GB1 D D 0 0

D - No treaty available. Domestic rates apply. | N/A - Country does not apply withholding tax.

Asia

Afric

aEu

rope

Mid

dle E

ast

Int

er

es

tIntereSt | DIvIDenDS | royAltIeS Africa | A 21

AN1 Interest paid to non-resident companies are subject to withholding tax at a rate of 15%. However, certain interest, such as interest on shareholders loans and bank deposits, are subject to a 10% rate.

BA1 Interest payments are not subject to WHT in Bahrain.

CM1 The standard rate is 15% plus local authority surcharge, making an actual tax of 16.5%.

CN1 A 10% withholding tax applies to interest paid to a non-resident. A 6% VAT also applies to interest payments.

DE1 Germany generally does not impose withholding tax on interest payments, except for interest on convertible or profit-sharing bonds and over-the-counter transactions where the rate of 25% applies.

GB1 A 20% WHT is applicable on interest payments to non-residents. However, there are a number of exceptions (e.g. payments of interest that qualify for exemption under the EU interest and Royalties Directive, payments of ‘short’ interest, etc.).

HK1 Hong Kong does not levy withholding tax on interest.

IN1 The 20% rate applies with respect to interest on monies borrowed or debts incurred in foreign currency by an Indian concern or the Government. For foreign company, this rate is increased by a surcharge of 2% (when the aggregate income exceeds INR 10 million) or 5% (when the aggregate income exceeds INR 100 million) and is further increased by an education cess of 4% (on income tax and surcharge). A special reduced rate of 5% applies under certain specified circumstances (including interest paid on specific borrowings in foreign currency and interest on investments made by a foreign institutional investor or a qualified foreign investor in a rupee-denominated bond of an Indian company, or in a Government security). In other cases, depending on whether the recipient is a corporate entity, a tax rate of 30% or 40% applies. These tax rates are increased the applicable surcharge and cess.

KE1 Interest paid to banks are exempt from WHT.

KR1 Interest paid to a non-resident generally is subject to a 20% withholding tax, plus the 10% local surtax, bringing the effective rate to 22%.

MU1 The general rate of withholding on interest is 15%, although a 0% rate applies to interest specifically exempted.

MY1 A withholding tax of 15% applies to interest paid to a non-resident, unless the rate is reduced under a tax treaty. However, interest paid to a non-resident by a bank operating in Malaysia is exempt from tax, except for interest accruing to the non-resident’s place of business in Malaysia and interest paid on funds required to maintain “net working funds,” as prescribed by the central bank. Certain other interest paid to a non-resident also may be exempt.

PN1 Generally, interest paid to non-resident foreign corporation is subject to 30% final withholding tax. For interest paid on foreign loans, the tax rate shall be 20% final withholding tax.

SG1 Interest paid to a non-resident is subject to a 15% withholding tax, unless the rate is reduced under a tax treaty or an exemption applies under certain domestic concessions. The 15% withholding tax is a final tax and applies only to interest not derived by the non-resident from a business carried on in Singapore and not effectively connected to a permanent establishment (PE) in Singapore. Any other interest that does not qualify for the final rate will be taxed at the prevailing corporate tax rate.

SG35 The 0% rate applies to interest paid to any institution or corporation wholly or mainly owned by Libya as may be agreed from time to time between Singapore and Libya.

TH1 Interest paid to a non-resident company is subject to a 15% withholding tax, unless the rate is reduced under a tax treaty. Interest paid on loans from a bank, financial institution or an insurance company is subject to a 10% withholding tax rate if the lender is resident in a country that has concluded a tax treaty with Thailand, but an exemption applies if the interest is paid by the Government or a Thai financial institution on loans granted under a law intended to promote agriculture, industry or commerce.

TW1 A 15% withholding tax applies to interest paid to a non-resident on short-term bills; interest on securitised certificates; interest on corporate bonds, Government bonds or financial debentures; and interest derived from repurchase transactions for these bonds or certificates.

UAE1 UAE does not impose withholding tax on interest payments.

ZA1 0% withholding tax applies if paid by a mining company.

Double Taxation Treaty Handbook For Corporate Withholding Tax

Domestic Rate (%) Treaty Rate (%)

To › Madagascar Malawi

from Corp - Corp Corp - Bank Corp - Corp Corp - Bank

Australia 10 D D D D

Bangladesh 20 D D D D

Brunei 2.5 D D D D

Cambodia 14 D D D D

China 10CN1 D D D D

Hong Kong 0HK1 D D D D

India 5/20/30/40IN1 D D D D

Indonesia 20 D D D D

South Korea 20KR1 D D D D

Macau N/A D D D D

Malaysia (Incl. Labuan) 0/15MY1 D D D D

Philippines 20/30PN1 D D D D

Singapore 0/15SG1 D D D D

Sri Lanka 14 D D D D

Taiwan 15/20TW1 D D D D

Thailand 0/10/15TH1 D D D D

Vietnam 5 D D D D

Angola 10/15AN1 D D D D

Botswana 15 D D D D

Cameroon 16.5CM1 D D D D

Gambia 15 D D D D

Ghana 8 D D D D

Ivory Coast 18 D D D D

Kenya 0/15KE1 D D D D

Mauritius 0/15MU1 10 10 D D

Nigeria 10 D D D D

Sierra Leone 15 D D D D

South Africa 15 D D D D

Tanzania 10 D D D D

Uganda 15 D D D D

Zambia 0/20ZA1 D D D D

Zimbabwe 0 D D D D

Bahrain N/ABA1 D D D D

Iraq 15 D D D D

Jordan 10 D D D D

Oman 10 D D D D

Pakistan 10 D D D D

Qatar 5 D D D D

United Arab Emirates (Incl. DIFC) N/AUAE1 D D D D

Germany 0/25DE1 D D D D

United Kingdom 0/20GB1 D D 0/DGB15 0

D - No treaty available. Domestic rates apply. | N/A - Country does not apply withholding tax.

Asia

Afric

aEu

rope

Mid

dle E

ast

Int

er

es

tIntereSt | DIvIDenDS | royAltIeS Africa | A 23

AN1 Interest paid to non-resident companies are subject to withholding tax at a rate of 15%. However, certain interest, such as interest on shareholders loans and bank deposits, are subject to a 10% rate.

BA1 Interest payments are not subject to WHT in Bahrain.

CM1 The standard rate is 15% plus local authority surcharge, making an actual tax of 16.5%.

CN1 A 10% withholding tax applies to interest paid to a non-resident. A 6% VAT also applies to interest payments.

DE1 Germany generally does not impose withholding tax on interest payments, except for interest on convertible or profit-sharing bonds and over-the-counter transactions where the rate of 25% applies.

GB1 A 20% WHT is applicable on interest payments to non-residents. However, there are a number of exceptions (e.g. payments of interest that qualify for exemption under the EU interest and Royalties Directive, payments of ‘short’ interest, etc.).

GB15 The domestic rate applies where the payment is made to a company that controls, directly or indirectly, more than 50% of the voting power in the payer company.

HK1 Hong Kong does not levy withholding tax on interest.

IN1 The 20% rate applies with respect to interest on monies borrowed or debts incurred in foreign currency by an Indian concern or the Government. For foreign company, this rate is increased by a surcharge of 2% (when the aggregate income exceeds INR 10 million) or 5% (when the aggregate income exceeds INR 100 million) and is further increased by an education cess of 4% (on income tax and surcharge). A special reduced rate of 5% applies under certain specified circumstances (including interest paid on specific borrowings in foreign currency and interest on investments made by a foreign institutional investor or a qualified foreign investor in a rupee-denominated bond of an Indian company, or in a Government security). In other cases, depending on whether the recipient is a corporate entity, a tax rate of 30% or 40% applies. These tax rates are increased the applicable surcharge and cess.

KE1 Interest paid to banks are exempt from WHT.

KR1 Interest paid to a non-resident generally is subject to a 20% withholding tax, plus the 10% local surtax, bringing the effective rate to 22%.

MU1 The general rate of withholding on interest is 15%, although a 0% rate applies to interest specifically exempted.

MY1 A withholding tax of 15% applies to interest paid to a non-resident, unless the rate is reduced under a tax treaty. However, interest paid to a non-resident by a bank operating in Malaysia is exempt from tax, except for interest accruing to the non-resident’s place of business in Malaysia and interest paid on funds required to maintain “net working funds,” as prescribed by the central bank. Certain other interest paid to a non-resident also may be exempt.

PN1 Generally, interest paid to non-resident foreign corporation is subject to 30% final withholding tax. For interest paid on foreign loans, the tax rate shall be 20% final withholding tax.

SG1 Interest paid to a non-resident is subject to a 15% withholding tax, unless the rate is reduced under a tax treaty or an exemption applies under certain domestic concessions. The 15% withholding tax is a final tax and applies only to interest not derived by the non-resident from a business carried on in Singapore and not effectively connected to a permanent establishment (PE) in Singapore. Any other interest that does not qualify for the final rate will be taxed at the prevailing corporate tax rate.

TH1 Interest paid to a non-resident company is subject to a 15% withholding tax, unless the rate is reduced under a tax treaty. Interest paid on loans from a bank, financial institution or an insurance company is subject to a 10% withholding tax rate if the lender is resident in a country that has concluded a tax treaty with Thailand, but an exemption applies if the interest is paid by the Government or a Thai financial institution on loans granted under a law intended to promote agriculture, industry or commerce.

TW1 A 15% withholding tax applies to interest paid to a non-resident on short-term bills; interest on securitised certificates; interest on corporate bonds, Government bonds or financial debentures; and interest derived from repurchase transactions for these bonds or certificates.

UAE1 UAE does not impose withholding tax on interest payments.

ZA1 0% withholding tax applies if paid by a mining company.

Double Taxation Treaty Handbook For Corporate Withholding Tax

Domestic Rate (%) Treaty Rate (%)

To › Mauritius

from Corp - Corp Corp - Bank

Australia 10 D D

Bangladesh 20 DBD11 DBD11

Brunei 2.5 D D

Cambodia 14 D D

China 10CN1 0/10CN37 0/10CN37

Hong Kong 0HK1 D D

India 5/20/30/40IN1 0 /7.5IN29 0 /7.5IN29

Indonesia 20 D D

South Korea 20KR1 D D

Macau N/A D D

Malaysia (Incl. Labuan) 0/15MY1 0/15MY25 0/15MY25

Philippines 20/30PN1 D D

Singapore 0/15SG1 0 0

Sri Lanka 14 0/10LK17 0/10LK17

Taiwan 15/20TW1 D D

Thailand 0/10/15TH1 0/10/15TH33 0/10TH33

Vietnam 5 D D

Angola 10/15AN1 D D

Botswana 15 0/12BO4 0/12BO4

Cameroon 16.5CM1 D D

Gambia 15 D D

Ghana 8 D D

Ivory Coast 18 D D

Kenya 0/15KE1 D D

Mauritius 0/15MU1

Nigeria 10 D D

Sierra Leone 15 D D

South Africa 15 0/10SA12 0/10SA12

Tanzania 10 D D

Uganda 15 10 10

Zambia 0/20ZA1 10 10

Zimbabwe 0 10 0

Bahrain N/ABA1 D D

Iraq 15 D D

Jordan 10 D D

Oman 10 0 0

Pakistan 10 0/10PK25 0/10PK25

Qatar 5 0 0

United Arab Emirates (Incl. DIFC) N/AUAE1 0 0

Germany 0/25DE1 0 0

United Kingdom 0/20GB1 D 0

D - No treaty available. Domestic rates apply. | N/A - Country does not apply withholding tax.

Asia

Afric

aEu

rope

Mid

dle E

ast

Int

er

es

tIntereSt | DIvIDenDS | royAltIeS Africa | A 25

AN1 Interest paid to non-resident companies are subject to withholding tax at a rate of 15%. However, certain interest, such as interest on shareholders loans and bank deposits, are subject to a 10% rate.

BA1 Interest payments are not subject to WHT in Bahrain.BO4 The 0% rate applies to interest paid in respect of a loan

granted or guaranteed by a financial institution of a public character with the objective of promoting exports and development, if the credit granted or guaranteed contains an element of subsidy.

BD11 The treaty does not provide a maximum rate on interest so the domestic rate applies.

CM1 The standard rate is 15% plus local authority surcharge, making an actual tax of 16.5%.

CN1 A 10% withholding tax applies to interest paid to a non-resident. A 6% VAT also applies to interest payments.

CN37 The 0% rate applies to interest paid to any financial institution wholly owned by that Government, or by any other financial institution agreed upon by the competent authorities of the Contracting States, or to any other resident with respect to debt-claims indirectly financed by the Government, a local authority, and the Central Bank thereof or any financial institution wholly owned by the Government, or by any other financial institution agreed upon by the competent authorities of the Contracting States.

DE1 Germany generally does not impose withholding tax on interest payments, except for interest on convertible or profit-sharing bonds and over-the-counter transactions where the rate of 25% applies.

GB1 A 20% WHT is applicable on interest payments to non-residents. However, there are a number of exceptions (e.g. payments of interest that qualify for exemption under the EU interest and Royalties Directive, payments of ‘short’ interest, etc.).

HK1 Hong Kong does not levy withholding tax on interest.IN1 The 20% rate applies with respect to interest on monies

borrowed or debts incurred in foreign currency by an Indian concern or the Government. For foreign company, this rate is increased by a surcharge of 2% (when the aggregate income exceeds INR 10 million) or 5% (when the aggregate income exceeds INR 100 million) and is further increased by an education cess of 4% (on income tax and surcharge). A special reduced rate of 5% applies under certain specified circumstances (including interest paid on specific borrowings in foreign currency and interest on investments made by a foreign institutional investor or a qualified foreign investor in a rupee-denominated bond of an Indian company, or in a Government security). In other cases, depending on whether the recipient is a corporate entity, a tax rate of 30% or 40% applies. These tax rates are increased the applicable surcharge and cess.

IN29 The 0% rate applies to interest (a) in respect of debt-claims existing on or before 31 March 2017 paid to a bank carrying on bona fide banking business; (b) paid to any person who is a resident provided that the transaction giving rise to the debt-claim has been approved in this regard by the Government of India.

KE1 Interest paid to banks are exempt from WHT.KR1 Interest paid to a non-resident generally is subject to a

20% withholding tax, plus the 10% local surtax, bringing the effective rate to 22%.

LK17 The 0% rate applies to interest paid to a bank, institution, body or board wholly and directly or indirectly owned by the Government or a local authority or in respect of a loan made, guaranteed / insured / credit extended, guaranteed / insured, by any credit agency or other financial institution as agreed between the States.

MU1 The general rate of withholding on interest is 15%, although a 0% rate applies to interest specifically exempted.

MY1 A withholding tax of 15% applies to interest paid to a non-resident, unless the rate is reduced under a tax treaty. However, interest paid to a non-resident by a bank operating in Malaysia is exempt from tax, except for interest accruing to the non-resident’s place of business in Malaysia and interest paid on funds required to maintain “net working funds,” as prescribed by the central bank. Certain other interest paid to a non-resident also may be exempt.

MY25 The 0% rate applies to interest paid to institutions of which the capital is wholly owned by the Government of Mauritius, or the local authorities or the statutory body thereof, as may be agreed upon from time to time between the competent authorities of the Contracting States, or if the loan or other indebtedness in respect of which the interest is paid is an approved loan or a long-term loan as defined under Malaysian Law.

PK25 The 0% rate applies to interest paid to agency or instrumentality of the Government as may be agreed in writing between Pakistan and Mauritius.

PN1 Generally, interest paid to non-resident foreign corporation is subject to 30% final withholding tax. For interest paid on foreign loans, the tax rate shall be 20% final withholding tax.

SA12 The 0% rate applies to interest paid in respect of a debt instrument listed on a recognised stock exchange (as defined).

SG1 Interest paid to a non-resident is subject to a 15% withholding tax, unless the rate is reduced under a tax treaty or an exemption applies under certain domestic concessions. The 15% withholding tax is a final tax and applies only to interest not derived by the non-resident from a business carried on in Singapore and not effectively connected to a permanent establishment (PE) in Singapore. Any other interest that does not qualify for the final rate will be taxed at the prevailing corporate tax rate.

TH1 Interest paid to a non-resident company is subject to a 15% withholding tax, unless the rate is reduced under a tax treaty. Interest paid on loans from a bank, financial institution or an insurance company is subject to a 10% withholding tax rate if the lender is resident in a country that has concluded a tax treaty with Thailand, but an exemption applies if the interest is paid by the Government or a Thai financial institution on loans granted under a law intended to promote agriculture, industry or commerce.

TH33 The 0% rate applies to interest paid to any institution, body or board which is wholly owned by the Government, a local authority or a political subdivision. The 10% rate applies to interest paid to a financial institution (including an insurance company).

TW1 A 15% withholding tax applies to interest paid to a non-resident on short-term bills; interest on securitised certificates; interest on corporate bonds, Government bonds or financial debentures; and interest derived from repurchase transactions for these bonds or certificates.

UAE1 UAE does not impose withholding tax on interest payments.

ZA1 0% withholding tax applies if paid by a mining company.

Double Taxation Treaty Handbook For Corporate Withholding Tax

Domestic Rate (%) Treaty Rate (%)

To › Morocco Mozambique

from Corp - Corp Corp - Bank Corp - Corp Corp - Bank

Australia 10 D D D D

Bangladesh 20 D D D D

Brunei 2.5 D D D D

Cambodia 14 D D D D

China 10CN1 0/10CN40 0/10CN40 D D

Hong Kong 0HK1 D D D D

India 5/20/30/40IN1 0/10IN32 0/10IN32 0/10IN2 0/10IN2

Indonesia 20 0/10ID19 10 D D

South Korea 20KR1 0/10KR43 10 D D

Macau N/A D D 10 10

Malaysia (Incl. Labuan) 0/15MY1 10 10 D D

Philippines 20/30PN1 D D D D

Singapore 0/15SG1 10 10 D D

Sri Lanka 14 D D D D

Taiwan 15/20TW1 D D D D

Thailand 0/10/15TH1 D D D D

Vietnam 5 10 10 10 10

Angola 10/15AN1 D D D D

Botswana 15 D D D D

Cameroon 16.5CM1 D D D D

Gambia 15 D D D D

Ghana 8 D D D D

Ivory Coast 18 10 10 D D

Kenya 0/15KE1 D D D D

Mauritius 0/15MU1 D D 8 0

Nigeria 10 D D D D

Sierra Leone 15 D D D D

South Africa 15 D D 8 0

Tanzania 10 D D D D

Uganda 15 D D D D

Zambia 0/20ZA1 D D D D

Zimbabwe 0 D D D D

Bahrain N/ABA1 10 10 D D

Iraq 15 D D D D

Jordan 10 10 10 D D

Oman 10 10 10 D D

Pakistan 10 10 10 D D

Qatar 5 10 10 D D

United Arab Emirates (Incl. DIFC) N/AUAE1 10 10 0 0

Germany 0/25DE1 10 10 D D

United Kingdom 0/20GB1 10 10 D D

D - No treaty available. Domestic rates apply. | N/A - Country does not apply withholding tax.

Asia

Afric

aEu

rope

Mid

dle E

ast

Int

er

es

tIntereSt | DIvIDenDS | royAltIeS Africa | A 27

AN1 Interest paid to non-resident companies are subject to withholding tax at a rate of 15%. However, certain interest, such as interest on shareholders loans and bank deposits, are subject to a 10% rate.

BA1 Interest payments are not subject to WHT in Bahrain.

CM1 The standard rate is 15% plus local authority surcharge, making an actual tax of 16.5%.

CN1 A 10% withholding tax applies to interest paid to a non-resident. A 6% VAT also applies to interest payments.

CN40 The 0% rate applies to interest paid to any institution wholly or mainly owned by the Government of Morocco, as may be agreed from time to time between the competent authorities of the Contracting States as far as the loans in consideration of which the interest is paid are guaranteed by the Government of Morocco.

DE1 Germany generally does not impose withholding tax on interest payments, except for interest on convertible or profit-sharing bonds and over-the-counter transactions where the rate of 25% applies.

GB1 A 20% WHT is applicable on interest payments to non-residents. However, there are a number of exceptions (e.g. payments of interest that qualify for exemption under the EU interest and Royalties Directive, payments of ‘short’ interest, etc.).

HK1 Hong Kong does not levy withholding tax on interest.

ID19 The 0% rate applies to interest paid in connection with the sale on credit of industrial or scientific equipment.

IN1 The 20% rate applies with respect to interest on monies borrowed or debts incurred in foreign currency by an Indian concern or the Government. For foreign company, this rate is increased by a surcharge of 2% (when the aggregate income exceeds INR 10 million) or 5% (when the aggregate income exceeds INR 100 million) and is further increased by an education cess of 4% (on income tax and surcharge). A special reduced rate of 5% applies under certain specified circumstances (including interest paid on specific borrowings in foreign currency and interest on investments made by a foreign institutional investor or a qualified foreign investor in a rupee-denominated bond of an Indian company, or in a Government security). In other cases, depending on whether the recipient is a corporate entity, a tax rate of 30% or 40% applies. These tax rates are increased the applicable surcharge and cess.

IN2 The 0% rate applies to interest paid to any other institution as may be agreed upon from time to time between the competent authorities of the Contracting States through exchange of letters.

IN32 The 0% rate applies to interest paid to the Bank Al-Maghrib (the Central Bank of Morocco), the Northern Provinces Development Agency, the Central Popular Bank and its regional agencies, the National Bank of Economic Development, the Moroccan Bank of Foreign Trade, the Communal Equipment Fund, the Immovable and Hotel Credit and the Industrial Development Office; or any other institution as may be agreed from time to time between the competent authorities of the Contracting States.

KE1 Interest paid to banks are exempt from WHT.

KR1 Interest paid to a non-resident generally is subject to a 20% withholding tax, plus the 10% local surtax, bringing the effective rate to 22%.

KR43 The 0% rate applies to interest paid in connection with the sale on credit of any industrial or scientific equipment.

MU1 The general rate of withholding on interest is 15%, although a 0% rate applies to interest specifically exempted.

MY1 A withholding tax of 15% applies to interest paid to a non-resident, unless the rate is reduced under a tax treaty. However, interest paid to a non-resident by a bank operating in Malaysia is exempt from tax, except for interest accruing to the non-resident’s place of business in Malaysia and interest paid on funds required to maintain “net working funds,” as prescribed by the central bank. Certain other interest paid to a non-resident also may be exempt.

PN1 Generally, interest paid to non-resident foreign corporation is subject to 30% final withholding tax. For interest paid on foreign loans, the tax rate shall be 20% final withholding tax.

SG1 Interest paid to a non-resident is subject to a 15% withholding tax, unless the rate is reduced under a tax treaty or an exemption applies under certain domestic concessions. The 15% withholding tax is a final tax and applies only to interest not derived by the non-resident from a business carried on in Singapore and not effectively connected to a permanent establishment (PE) in Singapore. Any other interest that does not qualify for the final rate will be taxed at the prevailing corporate tax rate.

TH1 Interest paid to a non-resident company is subject to a 15% withholding tax, unless the rate is reduced under a tax treaty. Interest paid on loans from a bank, financial institution or an insurance company is subject to a 10% withholding tax rate if the lender is resident in a country that has concluded a tax treaty with Thailand, but an exemption applies if the interest is paid by the Government or a Thai financial institution on loans granted under a law intended to promote agriculture, industry or commerce.

TW1 A 15% withholding tax applies to interest paid to a non-resident on short-term bills; interest on securitised certificates; interest on corporate bonds, Government bonds or financial debentures; and interest derived from repurchase transactions for these bonds or certificates.

UAE1 UAE does not impose withholding tax on interest payments.

ZA1 0% withholding tax applies if paid by a mining company.

Double Taxation Treaty Handbook For Corporate Withholding Tax

Domestic Rate (%) Treaty Rate (%)

To › Namibia Nigeria

from Corp - Corp Corp - Bank Corp - Corp Corp - Bank

Australia 10 D D D D

Bangladesh 20 D D D D

Brunei 2.5 D D D D

Cambodia 14 D D D D

China 10CN1 D D 7.5 0/7.5CN42

Hong Kong 0HK1 D D D D

India 5/20/30/40IN1 10 10 D D

Indonesia 20 D D D D

South Korea 20KR1 D D 0/7.5KR48 0/7.5KR48

Macau N/A D D D D

Malaysia (Incl. Labuan) 0/15MY1 10 10 D D

Philippines 20/30PN1 D D 0/10PN25 0/10PN25

Singapore 0/15SG1 D D 7.5 7.5

Sri Lanka 14 D D D D

Taiwan 15/20TW1 D D D D

Thailand 0/10/15TH1 D D D D

Vietnam 5 D D D D

Angola 10/15AN1 D D D D

Botswana 15 D D D D

Cameroon 16.5CM1 D D D D

Gambia 15 D D D D

Ghana 8 D D D D

Ivory Coast 18 D D D D

Kenya 0/15KE1 D D D D

Mauritius 0/15MU1 10 0/10MU8 D D

Nigeria 10 D D

Sierra Leone 15 D D D D

South Africa 15 10 10 7.5 7.5

Tanzania 10 D D D D

Uganda 15 D D D D

Zambia 0/20ZA1 D D D D

Zimbabwe 0 D D D D

Bahrain N/ABA1 D D D D

Iraq 15 D D D D

Jordan 10 D D D D

Oman 10 D D D D

Pakistan 10 D D 15 15

Qatar 5 D D D D

United Arab Emirates (Incl. DIFC) N/AUAE1 D D D D

Germany 0/25DE1 0 0 D D

United Kingdom 0/20GB1 D D 12.5 12.5

D - No treaty available. Domestic rates apply. | N/A - Country does not apply withholding tax.

Asia

Afric

aEu

rope

Mid

dle E

ast

Int

er

es

tIntereSt | DIvIDenDS | royAltIeS Africa | A 29

AN1 Interest paid to non-resident companies are subject to withholding tax at a rate of 15%. However, certain interest, such as interest on shareholders loans and bank deposits, are subject to a 10% rate.

BA1 Interest payments are not subject to WHT in Bahrain.

CM1 The standard rate is 15% plus local authority surcharge, making an actual tax of 16.5%.

CN1 A 10% withholding tax applies to interest paid to a non-resident. A 6% VAT also applies to interest payments.

CN42 The 0% rate applies to interest paid to any financial institution wholly owned by the Government.

DE1 Germany generally does not impose withholding tax on interest payments, except for interest on convertible or profit-sharing bonds and over-the-counter transactions where the rate of 25% applies.

GB1 A 20% WHT is applicable on interest payments to non-residents. However, there are a number of exceptions (e.g. payments of interest that qualify for exemption under the EU interest and Royalties Directive, payments of ‘short’ interest, etc.).

HK1 Hong Kong does not levy withholding tax on interest.

IN1 The 20% rate applies with respect to interest on monies borrowed or debts incurred in foreign currency by an Indian concern or the Government. For foreign company, this rate is increased by a surcharge of 2% (when the aggregate income exceeds INR 10 million) or 5% (when the aggregate income exceeds INR 100 million) and is further increased by an education cess of 4% (on income tax and surcharge). A special reduced rate of 5% applies under certain specified circumstances (including interest paid on specific borrowings in foreign currency and interest on invest