Various tax treaties

20.02.2024

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

Greece – France

11.05.2022

30.12.2023

01.01.2024

15%

5% or 0%a

Japan – Algeria

07.02.2023

20.01.2024

01.01.2025

10%

7%

South Korea – Taiwan

17.11.2021

27.12.2023

01.01.2024

10%

10%

Turkey – Cambodia

27.02.2022

Not availableb

01.01.2024

10%

10%

Turkey – Sri Lanka

28.01.2022

11.12.2023

01.01.2024 (Turkey); 01.04.2024 (Sri Lanka)

10%

10%

a. The 0% rate is applicable if the recipient is the beneficial owner of the interest and if – among others – one of the following conditions is met: (a) such recipient is a Contracting State or a local or territorial authority thereof or one of their statutory bodies, the central bank of that State; or the interest is paid by such State or local or territorial authority or statutory body thereof; or (b) the interest is paid in respect of any debt-claim or loan guaranteed, insured or subsidised by a Contracting State or by another person acting on behalf of a Contracting State.

b. According to a press release of 26 December 2023, published by the General Department of Cambodia, the double tax treaty Cambodia – Turkey has entered into force.

Terminated double taxation treaties

Markets

Effective date of termination

Hungary – United States

In Official Gazette (Magyar Közlöny) No. 171 of 30 November 2023, Hungary repealed MT Decree 49/1979. (XII. 6.) on the promulgation of the Hungary – United States Income Tax Treaty (1979). The revocation of the decree entails the termination of the treaty.

01.01.2024

Russia – Denmark

The Russian Ministry of Foreign Affairs released an official statement confirming the termination of the Denmark – Russia Income and Capital Tax Treaty (1996) is effective from 1 January 2024.

01.01.2024

Russia – Latvia

The Russian Ministry of Foreign Affairs released an official statement confirming the termination of the Latvia - Russia Income and Capital Tax Treaty (2010) is effective 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.