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 | ||||
Luxembourg – Rwanda | 29.09.2021 | 14.02.2024 | 01.01.2025 | 10% | 10% |
Saudi Arabia – Slovak Republic | 13.11.2023 | 01.08.2024 | 01.01.2025 | 5% | 10% |
South Korea – Turkey | 22.10.2021 | 21.07.2024 | 01.01.2025 | 15% | 10% |
Spain – Paraguay | 25.03.2023 | 14.10.2024 | 01.01.2025 | 10% | 0%a or 5% |
a. The 0% rate is applicable inter alia if the payer of the interest is the state from which they originate, or one of its political subdivisions, local authorities, or public entities.
Terminated DTTs
Markets | Effective date of termination | |
Spain – Kyrgyzstan | According to a press release of 11 June 2024, published by the Spanish government, Kyrgyzstan has denounced the former USSR – Spain Income and Capital Tax Treaty (1985), in relations between Kyrgyzstan and Spain. Link: Spanish note | 01.01.2023 |
Suspended DTTs
Markets | Effective date of termination | |
Russia – United States | According to a press release of 17 June 2024, published by the United States Department of the Treasury, the United States have issued a formal notice to Russia in response to Russia's suspension of articles 1(4), 5-21, 23 and the final protocol of the Russia – United States Income and Capital Tax Treaty (1992). The United States confirms the suspension by mutual agreement, taking effect on 16 August 2024 with respect to taxes withheld at source and other taxes. The suspension will continue until the two governments decide otherwise. Link: United States’ Notification of Suspension, By Mutual Agreement, of the 1992 Tax Convention with Russia | U.S. Department of the Treasury | 16.08.2024 |
Russia – France | On 23 June 2024, France published a notice (in French) in Official Journal No. 0147 regarding Russia's suspension of articles 5-22, 24 and points 2-9 of the final protocol of the France – Russia Income and Capital Tax Treaty (1996). In its notice, France confirms the suspension of the above-mentioned treaty provisions by virtue of the reciprocity principle, taking effect on 8 August 2023. Link : Légifrance - Publications officielles - Journal officiel - JORF n° 0147 du 23/06/2024 (legifrance.gouv.fr) | 08.08.2023 |
Hungary – Belarus | On 3 June 2024, the Hungarian tax authorities published a statement (in Hungarian) from the Hungarian Ministry of Finance in response to Belarus's unilateral decision to suspend specific provisions of the Belarus – Hungary DTT. Hungary stated that Belarus would apply its domestic tax rate to payments regarding passive income from investments (dividends, interest and capital gains) instead of the withholding rates set by the treaty. Hungary, however, will continue to apply the provisions of, and ensure the benefits arising from, the treaty. Link: Tájékoztató a Belarusz Köztársaság és Magyarország közötti kettős adóztatás elkerüléséről szóló egyezmény részleges felfüggesztéséről - Nemzeti Adó- és Vámhivatal (gov.hu) | 03.06.2024 |
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. |