Various tax treaties
Double Taxation Treaties (DTTs) between the following markets were signed and came into force with the rates as indicated in the following table:
Markets | Date signed (conclusion date) | Date in force | Applicable (effective date) | General DTT | |
Rates (%) | |||||
Equities | Debt | ||||
Armenia – Switzerland | 12.11.2021 | 02.05.2023 | 01.01.2024 | 15% | 10% or 0%a |
Czech Republic – Kosovo | 26.11.2013 | 24.07.2023 | 01.01.2024 | 15% | 0% |
Japan – Azerbaijan | 27.12.2022 | 04.08.2023 | 01.01.2024 | 7%b | 7% or 0%c |
a. The 0% rate at source is applicable to income from debt claims that is paid (i) in connection with the sale on credit of any industrial, commercial or scientific equipment; (ii) on any loan of whatever kind granted by a bank; or (iii) to the government of the other treaty jurisdiction, its political subdivisions or local bodies, or its central bank.
b. 7% is applicable to income from equities (dividend) to the extent that such income is not deductible in computing the taxable income of the distributing company. The rate shall be 10% when the dividends are deductible in computing the taxable income of the distributing company.
c. The 0% rate at source is applicable to income from debt claims if the income is beneficially owned (i) by the other treaty jurisdiction, a political subdivision or local authority thereof, the central bank of the other treaty jurisdiction or any institution wholly owned by that other treaty jurisdiction or a political subdivision or local authority thereof; or (ii) by a resident of the other treaty jurisdiction with respect to debt claims guaranteed, insured or indirectly financed by that treaty jurisdiction, a political subdivision or local authority thereof, the central bank of that other treaty jurisdiction or any institution wholly owned by that other treaty jurisdiction or a political subdivision or local authority thereof.
Terminated double taxation treaties
Markets | Effective date of termination | |
Norway – Barbados | By way of a Royal Decree of 9 June 2023, Norway terminated the DTT Barbados - Norway (1990), as amended by the 2011 protocol. Per Article 32 of the DTT, the termination will take effect from 1 January 2024. | 01.01.2024 |
Norway – Curaçao | By way of a Royal Decree of 9 June 2023, Norway terminated the DTT Netherlands Antilles - Norway (1989), as amended by the 2009 protocol, regarding the relations between Curaçao and Norway. Per Article 31 of the DTT, the termination will take effect from 1 January 2024. | 01.01.2024 |
Norway – Jamaica | By way of a Royal Decree of 9 June 2023, Norway terminated the DTT Jamaica - Norway (1991), as amended by the 2012 protocol. Per Article 31 of the DTT, the termination will take effect from 1 January 2024. | 01.01.2024 |
Norway – Sierra Leone | By way of a Royal Decree of 9 June 2023, Norway terminated the DTT Norway - Sierra Leone (1955). Per Article 22 of the DTT, the termination will take effect from 1 January 2024 in Norway and 6 April 2024 in Sierra Leone. | Norway: 01.01.2024 Sierra Leone: 06.04.2024 |
Norway – Trinidad and Tobago | By way of a Royal Decree of 9 June 2023, Norway terminated the DTT Norway - Trinidad and Tobago (1969). Per Article 31 of the DTT, the termination will take effect from 1 January 2024. | 01.01.2024 |
Our Market DTT information will be updated in due course to reflect the new treaties.
This Taxflash is intended to provide clients with general information gathered from different sources that are generally believed to be reliable. Clearstream Banking S.A. does not guarantee the accuracy or completeness of the information and does not undertake to keep it up to date. Use of the information made available in this Taxflash is at the client’s own risk and Clearstream Banking S.A., its subsidiaries and affiliates expressly disclaim any liability for any errors or omissions reflected herein. The information in this Taxflash does not constitute legal or tax advice. |