Summary of Tax Treaty Rates As of 06 February 2015: Country Dividends Interest Royalties

Summary of Tax Treaty Rates
As of 06 February 2015
Country
Australia
Austria
Bahrain
Bangladesh
Belgium
Brazil
Canada
Chile
Dividends
Individuals
Qualifying
Companies
Companies
25%
15%1
25%
10%4
15%
10%7
15%
10%9
15%
10%10
25%
15%11
25%
15%14
15%
10%17
Interest
15%/10%2
15%/10%5
10%
15%
10%
15%/10%12
15%/10%15
10%
Royalties
25%/15%3
15%/10%6
15%8/10%
15%
15%
25%13/15%
25%16
15%181019
This rate applies if relief by way of either rebate or credit (in accordance with Article 24 of the
RP-Australia Tax Treaty) is granted to the beneficial owner of the dividends.
2
The lower rate applies to public issues of bonds, debentures or similar obligations, paid by a
Philippine company to an Australian resident.
3
The lower rate applies if the royalties are paid by an enterprise which is registered with the
Board of Investments and engaged in preferred areas of activities.
4
This rate applies if the beneficial owner is a company which holds directly at least 10% either of
the voting shares of the company paying the dividends or of the total shares issued by that
company during the period of six months immediately preceding the date of payments of the
dividends.
5
The lower rate applies to interest paid on public issues of bonds, debentures or similar
obligations; and to interest paid by a company registered with the Board of Investments and
engaged in preferred pioneer areas of investment under the investment incentives laws of the
Philippines.
6
The lower rate applies to royalties paid by a company registered with the Board of Investments
and engaged in preferred pioneer areas of investments under the investment incentives laws of
the Philippines.
7
This rate applies if the beneficial owner is a company (excluding partnerships) which holds
directly at least 10% of the capital of the paying company.
8
This rate applies to royalties arising from the use of, or the right to use, any copyright of literary,
artistic or scientific work including cinematograph films or tapes for television or broadcasting.
The rate is 10% for other royalties.
9
directly at least 25% of the capital of the company paying the dividends.
10
This rate applies if the beneficial owner is a company which holds directly at least 10% of the
capital of the company paying the dividends.
11
This rate applies if the recipient is a company including a partnership.
12
obligations.
13
This rate applies to royalties arising from the use or the right to use trade marks and
cinematograph films, films or tapes for television or radio broadcasting. The rate is 15% for other
royalties.
14
This rate applies if the beneficial owner is a resident of Canada which controls at least 10% of
the voting power of the company paying the dividend.
15
obligations.
16
This rate is subject to the most-favored-nation provision of the treaty.
17
This rate applies if if the beneficial owner is a company which holds directly at least 10 per cent
of the capital of the company paying the dividends
18
19
This rate applies to royalties arising from the use of, or the right to use, any patent, trade mark,
1

Country
China
Czech Republic
Denmark
Finland
France
Germany
Hungary
India
Dividends
Individuals
Qualifying
Companies
Companies
15%
10%20
15%
10%23
15%
10%26
15%
15%27
15%
10%30
15%
10%33
20%
15%37
20%
15%39
Interest
10%
10%
10%
15%/10%28
15%/10%31
15%/10%34
15%
15%/10%40
Royalties
15%21/10%22
15%24/10%25
15%
25%/15%29
25%/15%32
15%35/10%36
15%38
15%41
design or model, plan, secret formula or process, or from the use of, or the right to use, industrial,
commercial, or scientific equipment, or for information concerning industrial, commercial or
scientific experience.
20
21
22
scientific experience, provided that the contract giving rise to the royalties has been approved by
the Philippine competent authorities.
23
24
This rate applies to royalties arising from the use of, or the right to use, any copyright of
cinematograph films, and films or tapes for television or radio broadcasting.
25
This rate applies royalties arising from the use of, or the right to use, any copyright of literary,
artistic or scientific work (other than those mentioned in footnote no. Error: Reference source not
found), any patent, trade mark, design or model, plan, secret formula or process, or from the use
of, or the right to use, industrial, commercial or scientific equipment, or for information concerning
industrial, commercial or scientific experience.
26
This rate applies if the beneficial owner is a company (other than a partnership) which holds
27
This rate applies if the recipient is a company (excluding partnership) owning at least 10% of
the voting stock of the company paying the dividends.
28
The lower rate applies to interest on public issues of bonds, debentures or similar obligations.
29
The lower rate applies to royalties paid by an enterprise registered with and engaged in
preferred areas of activities and also to royalties in respect of cinematographic films or tapes for
television or broadcasting, and royalties for the use of, or the right to use any copyright of literary,
artistic or scientific work.
30
directly at least 10% of the voting shares of the company paying the dividends.
31
The lower rate applies with respect to public issues of bonds, debentures or similar obligations.
32
The lower rate applies if the royalties are paid by an enterprise registered with the Philippine
Board of Investments and engagded in preferred areas of activities; or paid in respect of
cinematographic works recorded for broadcasting or television
33
34
The lower rate applies to interest paid on the sale on credit of any industrial, commercial or
scientific equipment, or to any loan of whatever kind granted by a bank, or to public issues of
bonds, debentures or similar obligations.
35
2

Country
Indonesia
Israel
Italy
Japan
Korea
Malaysia
Myanmar
Netherlands
Dividends
Individuals
Qualifying
Companies
Companies
20%
15%42
15%
10%44
15%
15%
15%
10%48
25%
10%51
54
25%/15%
15%
15%
10%56
15%
10%57
Interest
Royalties
15%/
10%
15%/10%46
10%
15%/10%52
15%
25%/15%43
15%45
25%/15%47
15%49/1050
15%/10%53
25%/15%55
15%/10%58
15%/10%59
36
scientific experience.
37
38
39
This rate applies if the beneficial owner is a company which owns at least 10% of the shares of
the company paying the dividends.
40
The lower rate applies if the interest is received by a financial institution (including insurance
companies) or in respect of public issues of bonds, debentures or similar obligations.
41
This rate applies if the royalties are paid by an enterprise which is registered with the Board of
Investment.
42
capital of the paying company.
43
The lower rate applies to royalties paid by an enterprise registered with the Philippine Board of
Investments, and engaged in preferred areas of activities as determined by the said Board.
44
This rate applies if the beneficial owner is a company (excluding partnership) which holds
45
46
The lower rate applies to interest in respect of public issues of bonds, debentures, or similar
obligations.
47
The lower rate applies to royalties paid by an enterprise registered with the Philippine Board of
Investments and engaged in preferred areas of activities and also royalties in respect of
cinematographic films or tapes for television or broadcasting.
48
This rate applies if the beneficial owner is a company which holds directly at least 10% either of
the voting shares of the company paying the dividends or of the total shares issued by that
company during the period of six months immediately preceding the date of payment of the
dividends. This rate also applies if the dividends are paid by a company registered with the
Board of Investments and engaged in preferred pioneer areas of investment under the investment
laws of the Philippines.
49
This rate applies if the royalties are paid in respect of the use of or the right to use
cinematograph films and films or tapes for radio or television broadcasting
50
Lower rate applies for other royalties. This rate also applies if royalties were paid by companies
regeisters with the Board of Investments and engaged in preferred pioneer areas of investment
under the investment incentive laws of the Philippines.
51
This rate applies if the beneficial owner is a company (other than a partnership) which holds
directly at least 25% of the capital of the company paying the dividends. This rate applies also if
the dividends are paid by a company, being a resident of the Philippines, registered with the
Board of Investments and engaged in preferred pioneer areas of investment under the investment
incentives laws of the Philippines.
52
This rate applies to interest paid in respect of public issues of bonds, debentures or similar
obligation. This rate also applies to interest paid by a company, being a resident of the
3

Country
Nigeria
New Zealand
Norway
Pakistan
Poland
Qatar
Romania
Russian Federation
Dividends
Individuals
Qualifying
Companies
Companies
15%
12.5%60
15%
15%61
25%
15%64
25%
15%67
15%
10%70
15%
10%71
15%
10%72
15%
15%
Interest
10%62
15%
15%/10%68
10%
10%
15%/10%73
15%
Royalties
15%63
25%65/7.5%66
25%/15%69
15%
15%
25%/15%74/10%75
15%
Philippines, registered with the Board of Investments and engaged in preferred pioneer areas of
investment under the investment incentives laws of the Philippines.
53
The lower rate applies to royalties paid by a company registered with the Board of Investments
and engaged in preferred pioneer areas of investment under the investment incentives laws of
the Philippines.
54
This rate applies if the recipient is a company.
55
This rate applies to royalties paid by a registered enterprise and to royalties paid for the use of,
or the right to use, cinematograph films, or tapes for radio or television broadcasting.
56
This rate applies if the recipient is a company the capital of which is wholly or partially divided
into shares and which holds directly at least 10 per cent of the capital of the company paying the
dividends.
57
This rate applies if the recipient is a company the capital of which is wholly or partly divided into
shares and which holds directly at least 10% of the capital of the company paying the dividends.
However, if the company which is a resident to the Netherlands suffers Netherlands company tax
on the dividends which it receives from the company which is a resident of the Philippines, the
15% rate will apply.
58
The lower rate applies to interest in connection with the sale on credit of any industrial,
commercial or scientific equipment; on any loan of whatever kind granted by a bank, or any other
financial institution; or in respect of public issues of bonds, debentures or similar obligations.
59
The lower rate applies to royalties paid by an enterprise registered and engaged in preferred
areas of activities.
60
directly at least 10 per cent of the capital of the paying company.
61
This rate applies if the beneficial owner is a company.
62
This rate applies if the recipient is the beneficial owner of the interest.
63
This rate applies if the recipient is the beneficial owner of the royalties.
64
This rate applies if the beneficial owner is a company which controls directly or indirectly at
least 10% of the voting power in the company paying the dividends.
65
66
This rate applies to gross rentals or amount paid for the use of or the right to use containers.
67
This rate applies if the recipient is a company (excluding partnership) which holds 25% of the
capital of the paying company during the taxable year which precedes the date of payment of the
dividends and during the whole of its prior taxable year.
68
The lower rate applies if the interest is paid with respect to public issues of bonds, debentures
or similar obligations.
69
The lower rate applies if the royalties are paid by an enterprise registered with and engaged in
preferred areas of activities.
70
71
This rate applies if if the beneficial owner is a company (excluding partnerships) which holds
directly at least 10 per cent of the capital of paying company.
72
This rate applies if the recipient holds at least 25% of the outstanding shares of the voting stock
of the paying corporation during the taxable year which precedes the date of payment of the
4

Country
Singapore
Spain
Sweden
Switzerland
Thailand
Turkey
United Arab Emirate
United Kingdom
Dividends
Individuals
Qualifying
Companies
Companies
25%
15%76
15%
10%79
15%
10%83
15%
10%84
15%
20%85
15%
10%89
15%
10%92
25%
15%94
Interest
15%/10%77
15%/10%80
10%
10%
25%86/15%/10%87
10%
15%/ 10%93
15%/10%95
Royalties
25%/15%78
15%/20%81/10%82
15%
15%
25%/15%88
15%90/ 10%91
10%
25%/15%96
dividends and during the whole of its prior taxable year.

73
This rate applies to interest paid in connection with the sale on credit of any industrial,
commercial or scientific machine or equipment or similar installation; or on any loan of whatever
kind granted by a bank; or on public issues of bonds, debentures or similar obligations.
74
This rate applies to royalties paid on cinematographic films and tapes for television or
broadcasting.
75
This rate applies to royalties paid by an enterprise registered with the Board of Investments and
engaged in preferred pioneer areas of activities.
76
This rate applies if the recipient is a company (including partnership) which holds at least 15%
of the outstanding shares of the voting stock of the paying company during the taxable year which
precedes the date of payment of the dividends and during the whole of its prior taxable year.
77
The lower rate applies if the interest is paid with respect to public issues of bonds, debentures
or similar obligations.
78
This rate applies to royalties paid by an enterprise registered with the Board of Investments and
engaged in preferred pioneer areas of activities and also to royalties paid on cinematographic
films and tapes for television or broadcasting.
79
This rate applies if the if the recipient is a corporation (excluding partnership) which holds
directly at least 10% of the voting shares of the company paying the dividends.
80
This rate applies if the interest is paid in connection with the sale on credit of any industrial,
commercial or scientific equipment and in respect of issues of bonds, debentures or similar
obligations offered to the general public.
81
This rate applies to royalties paid on cinematographic films or tapes for television or
broadcasting.
82
This rate applies to royalties paid by an enterprise registered with the Philippine Board of
Investments and engaged in preferred areas of activities.
83
84
85
This rate applies if the Thai paying company is not engaged in an industrial undertaking
86
This rate applies if the interest arises from Thailand. Apply the 15% rate if the interest arises
from the Philippines.
87
The lower rate applies if the interest is in respect of public issues of bonds, debentures or
similar obligations.
88
Investments and engaged in preferred areas of activities; or in respect of cinematographic films or
tapes for television or broadcasting.
89
90
This rate applies for royalties arising from the use of, or the right to use, any cinematograph
films or tapes for television or radio broadcasting.
91
This rate applies for royalties arising from the use of, or the right to use, any copyright of
literary, artistic or scientific work, any patent, trade mark, design or model, plan, secret formula or
5

Country
United States of America
Vietnam
Yugoslavia
Dividends
Individuals
Qualifying
Companies
Companies
25%
20%97
15%
10%100
15%
10%101
Interest
15%/10%98
15%
10%
Royalties
25%/15%99
15%
15%
process, or from the use of, or the right to use, industrial, commercial, or scientific equipment, or
for information concerning industrial, commercial or scientific experience.
92
93
94
This rate applies if the beneficial owner is a company which controls directly or indirectly at
least 10% of the voting power in the company paying the dividends.
95
The lower rate applies if the interest is paid by a company in respect of the public issue of
bonds, debentures or similar obligations.
96
Investments and engaged in preferred areas of activity; or in respect of cinematograph films or
tapes for television or radio broadcasting.
97
This rate applies if the recipient is a corporation which holds at least 10% of the outstanding
shares of the voting stock of the paying corporation during the part of the paying corporations
taxable year which precedes the date of payment of the dividend and during the whole of its prior
taxable year.
98
This rate applies to interest with respect to public issues of bonded indebtedness.
99
This rate applies to royalties paid by a corporation registered with the Philippine Board of
Investments and engaged in preferred areas of activities. This rate is also subject to the mostfavored-nation provision on the treaty. In ITAD Ruling No. 101-03 dated July 24, 2003, the 15%
rate in the RP-Netherlands Tax Treaty and RP-China Tax Treaty may be applied under the mostfavored-nation provision of the RP-US Tax Treaty.
100
This rate applies if the recipient is the beneficial owner is a company (excluding partnerships)
which holds directly at least 25% of the capital of the paying company.
101
This rate apples if the beneficial owner is a company (excluding partnerships) which holds
6

Summary of Tax Treaty Rates As of 06 February 2015: Country Dividends Interest Royalties

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Summary of Tax Treaty Rates