01
Effective status
The 2010 agreement entered into force on 9 November 2011. The protocol of 12 June 2019 entered into force on 30 November 2020 and forms part of the current regime; a separate inheritance-tax treaty also remains in place.
This editorial overview does not replace the official treaty and protocol, domestic law or a factual analysis of the income recipient.
02
Dividends
General limit 15%; 0% for a company holding at least 10%, subject to the treaty's anti-abuse conditions.
03
Interest
Treaty limit 0%.
04
Royalties
Treaty limit 0%.
05
Applying the treaty
Beneficial ownership, the 10% holding, the purpose of the intercompany link and the updated anti-abuse rules are central to the zero corporate-dividend rate. Funds, FCPs, SICAVs and real-estate structures require separate classification under competent-authority agreements. A treaty rate is a maximum source-state limit, not an automatic rate. Before payment, test residence, beneficial ownership, minimum holding and holding period, PPT, substance, domestic law and the relief-at-source, notification or refund procedure.
06
Practical sequence
- Determine residence and the relevant tax period
- Classify the income and beneficial recipient
- Test the holding, holding period, PPT and business purpose
- Prepare certificates, forms and substance evidence
- Coordinate withholding, notification or refund and MAP where needed
↗