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
Greece – France
11.05.2022
30.12.2023
01.01.2024
15%
5% or 0%a
Japan – Algeria
07.02.2023
20.01.2024
01.01.2025
10%
7%
South Korea – Taiwan
17.11.2021
27.12.2023
01.01.2024
10%
10%
Turkey – Cambodia
27.02.2022
Not availableb
01.01.2024
10%
10%
Turkey – Sri Lanka
28.01.2022
11.12.2023
01.01.2024 (Turkey); 01.04.2024 (Sri Lanka)
10%
10%
a. The 0% rate is applicable if the recipient is the beneficial owner of the interest and if – among others – one of the following conditions is met: (a) such recipient is a Contracting State or a local or territorial authority thereof or one of their statutory bodies, the central bank of that State; or the interest is paid by such State or local or territorial authority or statutory body thereof; or (b) the interest is paid in respect of any debt-claim or loan guaranteed, insured or subsidised by a Contracting State or by another person acting on behalf of a Contracting State.
b. According to a press release of 26 December 2023, published by the General Department of Cambodia, the double tax treaty Cambodia – Turkey has entered into force.
Terminated double taxation treaties
Markets
Effective date of termination
Hungary – United States
In Official Gazette (Magyar Közlöny) No. 171 of 30 November 2023, Hungary repealed MT Decree 49/1979. (XII. 6.) on the promulgation of the Hungary – United States Income Tax Treaty (1979). The revocation of the decree entails the termination of the treaty.
01.01.2024
Russia – Denmark
The Russian Ministry of Foreign Affairs released an official statement confirming the termination of the Denmark – Russia Income and Capital Tax Treaty (1996) is effective from 1 January 2024.
01.01.2024
Russia – Latvia
The Russian Ministry of Foreign Affairs released an official statement confirming the termination of the Latvia - Russia Income and Capital Tax Treaty (2010) is effective from 1 January 2024.
01.01.2024
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.
↧