Cyprus and Netherlands | On 30 June 2023, the Double Taxation Agreement (DTA) between Cyprus and the Netherlands entered into force. The DTA contains withholding tax rates for Dividends 0% for at least 5% capital holding; otherwise, 15%, Interest 0%, and Royalties 0%. The DTA will be applicable from 1 January 2024. |
Benin, Czech Republic, and Rwanda | On 27 June 2023, the Rwandan parliament approved the Double Taxation Agreements (DTAs) with the Czech Republic and Benin. Following the President’s approval and subsequent promulgation, the DTA will be considered ratified in Rwanda. |
France and Switzerland | On 27 June 2023, Govt. officials from France and Switzerland signed an amending protocol to the Double Taxation Agreement (DTA). In particular, it brings the DTA into line with the results of the OECD’s efforts to combat base erosion and profit shifting (BEPS). |
Egypt and Oman | On 25 June 2023, Oman ratified the Double Taxation Agreement (DTA) with Egypt. |
Hong Kong and Mauritius | On 23 June 2023, the Double Taxation Agreement (DTA) between Hong Kong and Mauritius entered into force. The DTA contains withholding tax rates for Dividends 0% for at least 10% capital holding; otherwise, 5%, Interest 5%, and Royalties 5%. It will apply from 1 January 2024. The DTA applies from 1 July 2023 in Mauritius and from 1 April 2024 in Hong Kong. |
Brazil and Uruguay | On 23 June 2023, Brazil officially released Legislative Decree No. 72/2023 in the Official Gazette. This decree outlines the ratification of the Double Taxation Agreement (DTA) with Uruguay. |
Cambodia, Congo, DRC, Nigeria, Senegal, Sierra Leone, Sri Lanka, and Turkey | On 22 June 2023, the Turkish Grand National Assembly’s Foreign Affairs Committee successfully adopted a legislative proposal aimed at approving the ratification of the Double Taxation Agreements (DTAs) with Cambodia, Congo, DRC, Nigeria, Senegal, Sierra Leone, and Sri Lanka. |
France and Rwanda | On 22 June 2023, the Govt. officials from France and Rwanda signed a Double Taxation Agreement (DTA) for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. |
Chile and United States | On 22 June 2023, the Senate of the United States overwhelmingly voted 95-2 in favor of approving a Resolution of Advice and Consent to ratify the long-pending Double Taxation Agreement (DTA) with Chile. The DTA contains withholding tax rates for Dividends 5% for at least 10% voting stock; otherwise, 15%, Interest 15%, and Royalties 10%. |
Belgium and Netherlands | On 21 June 2023, the Govt. officials from Belgium and the Netherlands signed a Double Taxation Agreement (DTA). Once in force and effective, the new DTA will replace the former DTA of 2001. |
Czech Republic and Kosovo | On 21 June 2023, the Senate of the Czech Republic approved the bill for the ratification of the Double Taxation Agreement (DTA) with Kosovo. |
Luxembourg and Cape Verde | On 21 June 2023, the Government Council of Luxembourg gave its approval for the ratification of the Double Taxation Agreement (DTA) with Cape Verde. |
France and Luxembourg | On 19 June 2023, Luxembourg ratified the amending protocol to the Double Taxation Agreement (DTA) with France. |
Syria and Ukraine | On 16 June 2023, the Ministry of Finance of Ukraine issued a press release stating that the Ukrainian government has given its approval to a draft law concerning the termination of the Double Taxation Agreement (DTA) with Syria. |
Germany and Mexico | On 15 June 2023, Mexico ratified the amending protocol to the Double Taxation Agreement (DTA) with Germany. |
Belarus and Ukraine | On 15 June 2023, the lower house of the Belarusian parliament approved the draft law for the termination of the Double Taxation Agreement (DTA) with Ukraine. However, the DTA has already been terminated in practice since 1 January 2023. |
Belarus and Zimbabwe | On 15 June 2023, the lower house of parliament of Belarus approved the ratification of the Double Taxation Agreement (DTA) with Zimbabwe. |
Bulgaria, Germany, Latvia, and Lithuania | On 14 June 2023, the lower house of the German parliament granted approval for the ratification of the pending protocols to the Double Taxation Agreements (DTAs) with Bulgaria, Latvia, and Lithuania. |
Denmark and Russia | On 13 June 2023, the Queen of Denmark officially approved Law Nr. 712, granting authorization for the termination of the Double Taxation Agreement (DTA) with Russia. This law was published in the Official Gazette on June 14, 2023. |
Oman and Russia | On 8 June 2023, the Govt. officials from Oman and Russia signed a Double Taxation Agreement (DTA). The DTA contains withholding tax rates for Dividends 10% for at least 20% capital holding; otherwise, 15%, Interest 10%, and Royalties 10%. |
Azerbaijan and Slovak Republic | On 7 June 2023, the Double Taxation Agreement (DTA) between Azerbaijan and the Slovak Republic was signed. |
Qatar and Ukraine | On 6 June 2023, Ukraine ratified the pending protocol to the Double Taxation Agreement (DTA) with Qatar. The protocol becomes effective upon the exchange of ratification instruments and will be applicable from the 1st of January in the year following its entry into force. |
Qatar and Uzbekistan | On 6 June 2023, the Govt. officials from Qatar and Uzbekistan signed a Double Taxation Agreement (DTA) for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. |
Switzerland and Tajikistan | On 1 June 2023, the Swiss National Assembly approved the amending protocol to the Double Taxation Agreement (DTA) with Tajikistan. |
Ethiopia, Luxembourg, and Switzerland | On 30 May 2023, the Ethiopian House of Representatives approved the Double Taxation Agreements (DTAs) with Luxembourg and Switzerland. |
Georgia and Kyrgyzstan | On 29 May 2023, the Double Taxation Agreement (DTA) between Georgia and Kyrgyzstan entered into force. The DTA contains withholding tax rates for Dividends 5% for at least 25% capital holding; otherwise, 10%, Interest 5%, and Royalties 10%. It will apply from 1 January 2024. |
Armenia and Switzerland | On 2 May 2023, the amending protocol to the Double Taxation Agreement (DTA) between Armenia and Switzerland entered into force. The protocol will apply from 1 January 2024. |
Armenia and Kyrgyzstan | On 9 February 2022, the Double Taxation Agreement (DTA) between Armenia and Kyrgyzstan entered into force. This DTA was signed on 9 August 2019, that contains withholding tax rates for Dividends 10%, Interest 10%, and Royalties 10%. The DTA applies from 1 January 2023. |
Germany and Luxembourg | The German Federal Cabinet has given its approval for the signing of an amended protocol to the Double Taxation Agreement (DTA) with Luxembourg. |
Cambodia and Macau | The Cambodian General Department of Taxation has officially declared that the Double Taxation Agreement (DTA) with Macau entered into force and will be applicable from 1 January 2024. This DTA was signed on 23 April 2021, that contains withholding tax rates for Dividends 10%, Interest 10%, Royalties 10%, and Fees for technical services 10%. |
Tax Treaty Brief: July 2023
20 July, 2023