Country

Dividends

Royalties

Interest

Austria

Nil – 10% ⁽¹²⁾

3%

Nil

Belgium

5 - 15% ⁽¹⁾

5%

10%

Brunei Darussalam

Nil

5%

5 - 10% ⁽²⁾

Hungary

5 – 10% ⁽¹⁰⁾

5%

5%

Indonesia

5 – 10% ⁽³⁾

5%

10%

Kuwait

0 - 5% ⁽¹¹⁾

5%

5%

Luxembourg

0 - 10% ⁽⁵⁾

3%

Nil

Mainland of China

5 – 10% ⁽⁴⁾

7%

7%

Netherlands

0 - 10% ⁽⁶⁾

3%

Nil

Thailand

10%

5 – 10% ⁽⁸⁾

10 – 15% ⁽⁷⁾

Vietnam

10%

7 – 10% ⁽⁹⁾

10%

United Kingdom

0 - 10% ⁽¹³⁾

3%

Nil

Ireland

0

3%

10 – 15% ⁽¹⁴⁾

Liechtenstein

0

0%

0%

France

10%

10%

10%

Japan

5% ⁽¹⁵⁾

5%

10%

Switzerland

0 - 10% ⁽¹⁶⁾

3%

0%

Portugal

5 - 10% ⁽¹⁷⁾

5%

10%

Spain

0 - 10% ⁽¹⁸⁾

5%

5%

Czech Republic

5%

10%

0%

Note (1)

5% if the beneficial owner is a company which directly holds at least 10% of the capital of the company paying the dividends.  In all other cases 15%.

Note (2)

5% if the recipient is a bank or financial institution.  In all other cases 10%.

Note (3)

5% if the beneficial owner is a company directly owning at least 25% of the capital of the company paying the dividend.  In all other cases 10%.

Note (4)

5% if the beneficial owner is a company which directly holds at least 25% of the capital of the company paying the dividends.  In all other cases 10%.

Note (5)

0% if the beneficial owner is a company directly owning at least 10% of the capital of the company paying the dividends or a participation with an acquisition cost of at least EUR1.2 million in the company paying the dividends.  In all other cases 10%.

Note (6)

0% if the beneficial owner is a company directly owning at least 10% of the capital of the company paying the dividends provided that;

• the shares are traded on a recognized stock exchange, or
• at least 50% of the shares in the qualifying recipient company are regularly traded on a recognized stock exchange.

In all other cases 10%.

Note (7)

10% if the recipient is a financial institution or insurance company, or in respect to an arms length transactions concerning the sale of equipment, merchandise or services.  In all other cases 15%.

Note (8)

5% if for the use of or the right to use, any copyright of literary, artistic or scientific work.  10% if for the use of, or the right to use, any patent, trademark, design or model, plan, secret formula or process, and 15% in all other cases.

Note (9)

7% if for the use of, or the right to use, any patent, design or model, plan, secret formula or process.  10% in all other cases.

Note (10)

5% if the beneficial owner is a company directly owning at least 10% of the capital of the company paying the dividends.  In all other cases 10%.

Note (11)

0% if the beneficial owner in the government, 5% in all other cases.

Note (12)

0% if the beneficial owner is a company which directly holds at least 10% of the capital of the company paying the dividends.  In all other cases 10%.

Note (13)

Except where the beneficial owner is a pension scheme dividends paid by property investment vehicles such as REITs will be subject to a withholding tax of 15%.

Note (14)

10% unless paid to HKMA, a body owned or funded by the Government of the HKSAR, a bank or financial institution, paid by a bank or a financial institution, paid in respect of a sale on credit or to a person providing pension benefits.

Note (15)

The withholding tax is capped at 5% for a company holding (directly or indirectly) for a period of six months at least 10% of the voting shares of the company paying the dividends, and 10% for other cases.

Note (16)

0% if the beneficial owner is a resident of the other contracting party and which holds at least 10% of the capital paying the dividends.  A pension fund or pension scheme.

Note (17)

5% if the beneficial owner is a company (other than a partnership) which holds directly at least 10% of the capital of the company paying the dividends.

Note (18)

The dividend withholding tax is reduced to 0% if the beneficial owner of the dividends is a company (other than a partnership) holding directly at least 25% of the capital of the company paying the dividend.