Taysun Corporate Services Ltd

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