Bangladesh and Hong Kong | On 30 August 2023, the Govt. officials from Bangladesh and Hong Kong signed a Double Taxation Agreement (DTA) for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. The DTA contains withholding tax rates for Dividends 10% for at least 10% capital holding; otherwise, 15%, Interest 10%, Royalties 10%, and Fees for Technical Services 10%. |
Saudi Arabia and Sri Lanka | On 29 August 2023, the Saudi Arabian Cabinet approved the Double Taxation Agreement (DTA) with Sri Lanka for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. |
Qatar and Uzbekistan | On 28 August 2023, Mr. Shavkat Mirziyoyev, the President of Uzbekistan signed Decree No. PP-288, ratifying the Double Taxation Agreement (DTA) with Qatar. |
Iran, Syria, and Ukraine | On 23 August 2023, in a press release it was announced that the Ukrainian parliament passed draft Laws to terminate the Double Taxation Agreements (DTAs) with Syria and Iran. |
United Arab Emirates and Czech Republic | On 23 August 2023, the Czech Republic Senate approved the Double Taxation Agreement (DTA) with the United Arab Emirates (UAE). Once in force and effective, the new DTA will replace the former DTA of 1996. |
Austria and Germany | On 21 August 2023, the Govt. officials from Austria and Germany signed an amending protocol to update the Double Taxation Agreement (DTA) between two countries. |
Germany and Switzerland | On 21 August 2023, the German Ministry of Finance declared the signing of an amending protocol to the Double Taxation Agreement (DTA) with Switzerland. |
Russia and United Kingdom | On 18 August 2023, the UK government issued an official statement in reaction to Russia’s unilateral decision to suspend specific provisions of the Double Taxation Agreement (DTA) between two countries. Russia has suspended substantially all material provisions of many of its Double Taxation Agreements by Presidential decree dated 8 August 2023. This action affects 38 countries’ Double Taxation Agreements including the 1994 UK-Russia Double Taxation Convention, in respect of which the UK received notification from Russia on 15 August 2023. |
Ethiopia and Switzerland | On 10 August 2023, the Double Taxation Agreement (DTA) between Ethiopia and Switzerland entered into force. The DTA contains withholding tax rates for Dividends 5% for at least 25% capital holding; otherwise, 15%, Interest 5%, and Royalties 5%. The DTA generally applies in Ethiopia from 8 July 2024 and in Switzerland from 1 January 2024. |
France and Rwanda | On 10 August 2023, Mr. Paul Kagame, the President of Rwanda ratified the Double Taxation Agreement (DTA) with France. It was published in Official Gazette No. Special Bis of 11 August 2023. |
Japan and Russia | On 9 August 2023, Japan formally expressed its disapproval to Russia, issuing an official protest and urging for the withdrawal of Russia’s decision to unilaterally suspend specific tax provisions under the Double Taxation Agreement (DTA) between two countries. |
Cyprus and Russia | On 9 August 2023, Cyprus issued a statement through its Ministry of Finance in response to Russia’s unilateral decision to suspend specific provisions of the Double Taxation Agreement (DTA) between two countries. Cyprus expressed serious concern regarding Russia’s recent action to unilaterally suspend provisions of the DTA. |
Burkina Faso and France | On 7 August 2023, Burkina Faso’s Ministry of Foreign Affairs formally notified France of its decision to terminate the Double Taxation Agreement (DTA) between the two countries. This decision came as a result of France’s unwillingness to engage in treaty renegotiations, despite Burkina Faso’s two previous requests for such discussions. Burkina Faso’s official notice to France specified that the termination would become effective within three months from the date of receipt. |
Moldova and Netherlands | On 7 August 2023, the President of Moldova granted authorization for the signing of an amending protocol to update the Double Taxation Agreement (DTA) with the Netherlands. |
Germany and Mexico | On 6 August 2023, the amending protocol to the Double Taxation Agreement (DTA) between Germany and Mexico entered into force. The protocol applies from 1 January 2024. |
Azerbaijan and Japan | On 4 August 2023, the Double Taxation Agreement (DTA) between Azerbaijan and Japan entered into force. The DTA contains withholding tax rates for Dividends 7%, Interest 7%, and Royalties 7%. The DTA generally applies from 1 January 2024. From this date, the new DTA replaced the existing DTA of 1986. |
Bulgaria, Germany, Latvia, and Lithuania | On 3 August 2023, Germany officially published the laws in the Official Gazette related to the ratification of the protocols to the Double Taxation Agreements (DTAs) with Bulgaria, Latvia, and Lithuania. These protocols aim to align the DTAs with OECD BEPS standards. |
Benin, Czech Republic, and Rwanda | On 2 August 2023, Mr. Paul Kagame, the President of Rwanda ratified the Double Taxation Agreements (DTAs) with the Czech Republic and Benin. |
Gambia and Senegal | On 1 August 2023, the Govt. officials from Gambia and Senegal signed a Double Taxation Agreement (DTA) for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. |
Germany and Luxembourg | On 28 July 2023, the Government Council of Luxembourg granted approval for the ratification of the amending protocol to the Double Taxation Agreement (DTA) with Germany. |
Czech Republic and Kosovo | On 24 July 2023, the Double Taxation Agreement (DTA) between the Czech Republic and Kosovo entered into force. The DTA contains withholding tax rates for Dividends 5% for at least 25% capital holding; otherwise, 15%, Interest 0%, and Royalties 10%. The DTA generally applies from 1 January 2024. |
Gabon and United Arab Emirates | On 16 February 2023, the Double Taxation Agreement (DTA) between the United Arab Emirates and Gabon entered into force. The DTA contains withholding tax rates for Dividends 10%, Interest 7%, Royalties 10%, and Fees for Technical Services 7.5%. The DTA generally applies from 1 January 2019. |
United Arab Emirates and Zambia | On 13 January 2023, the Double Taxation Agreement (DTA) between the United Arab Emirates and Zambia entered into force. The DTA contains withholding tax rates for Dividends 5%, Interest 5%, Royalties 5%, and Fees for Technical Services 5%. The DTA generally applies from 1 January 2023. |
Rwanda and United Arab Emirates | As per a recent notification from the United Arab Emirates (UAE) Ministry of Finance, the Double Taxation Agreement (DTA) with Rwanda entered into force on 4 December 2019. The DTA contains withholding tax rates for Dividends 7.5%, Interest 10%, Royalties 10%, and Fees for Technical Services 10%. The DTA generally applies from 1 January 2019. |
Tax Treaty Brief: September 2023
20 September, 2023