Tax Treaty Network
Highlight of Tax Treaties
| Country | Minimum Duration to constitute permanent establishement | Maximum Tax Rates applicable in the State of Source | |||
| Building Site etc | Furnishing of services | Dividends | Interest* | Royalties | |
| Barbados | > 6 months | 5% | 5% | 5% | |
| Belgium | > 6 months | 5% & 10% | 10% | Exempt | |
| Botswana | > 6 months | 6 months | 5% & 10% | 12% | 12.5% |
| China | > 12 months | 12 months | 5% | 10% | 10% |
| Croatia | > 12 months | Exempt | Exempt | Exempt | |
| Cyprus | > 12 months | 9 months | Exempt | Exempt | Exempt |
| France | > 6 months | 5% & 15% | same rate as under domestic law | 15% | |
| Germany | > 6 months | 5% & 15% | same rate as under domestic law | 15% | |
| India | > 9 months | 5% & 15% | same rate as under domestic law | 15% | |
| Italy | > 6 months | 5% & 15% | same rate as under domestic law | 15% | |
| Kuwait | > 9 months | Exempt | Exempt | 10% | |
| Lesotho | > 6 months | 6 months | 10% | 10% | 10% |
| Luxembourg | > 6 months | 5% & 10% | Exempt | Exempt | |
| Madagascar | > 6 months | 5% & 10% | 10% | 5% | |
| Malaysia | > 6 months | 5% & 15% | 15% | 15% | |
| Mozambique | > 6 months | 6 months | 8%, 10% & 15% | 8% | 5% |
| Namibia | > 6 months | 6 months | 5% & 10% | 10% | 5% |
| Nepal | > 6 months | 6 months | 5%, 10% & 15% | 10% & 15% | 15% |
| Oman | > 6 months | Exempt | Exempt | Exempt | |
| Pakistan | > 6 months | 10% | 10% | 12.5% | |
| Rwanda | > 12 months | 12 months | Exempt | Exempt | Exempt |
| Senegal | > 9 months | 9 months | Exempt | Exempt | Exempt |
| Seychelles | > 12 months | 6 months | Exempt | Exempt | Exempt |
| Singapore | > 9 months | Exempt | Exempt | Exempt | |
| South Africa | > 9 months | 5% & 15% | Exempt | Exempt | |
| Sri Lanka | > 6 months | 6 months | 10% & 15% | 10% | 10% |
| State of Qatar | > 6 months | 6 months | Exempt | Exempt | 5% |
| Swaziland | > 6 months | 6 months | 7.5% | 5% | 7.5% |
| Sweden | > 6 months | 5% & 15% | 15% | 15% | |
| Thailand | > 6 months | 6 months | 10% | 10% & 15% | 5% & 15% |
| Tunisia | > 12 months | Exempt | 2.5% | 2.5% | |
| Uganda | > 6 months | 4 months | 10% | 10% | 10% |
| United Arab Emirates | > 12 months | 12 months | Exempt | Exempt | Exempt |
| United Kingdom | > 6 months | 10% & 15% | Same rate as under domestic law | 15% | |
| Zimbabwe | > 6 months | 10% & 20 % | 10% | 15% | |
(a) Lower rates applies to companies holding at least 10% capital.
(b) Lower rates applies to companies holding at least 25% capital.
(c) Lower rates applies to companies holding at least 20% capital.
(d) Lower rates applies to companies holding at least 15% capital.
(e) Lower rates applies if paid to any Bank carrying on a bona fide banking business.
(f) Higher rates applies to companies holding investment other than portfolio investment.
* Where interest is taxable at rate provided in the domestic law of the State of source or at reduced treaty rate, provision is usually made in the treaty to exempt interest receivable by a Contracting State itself, its local authorities, its Central Bank/all banks carrying on bona fide banking business and any other financial institutions as may be agreed upon by both Contracting States.
Source: http://www.gov.mu/portal/sites/mra/dta.htm
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