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a)ÌýÌýÌý For payments made after 23 April 2010, the statutory withholding tax on interest paid to a foreign entity without a PE in Greece is increased from 25% to 40%.

b)ÌýÌý Generally applies to interest paid on a corporate bond that is traded on stock exchange, to the Government, Central Bank, or to a pension fund.

c)ÌýÌýÌý Applies to interest on public bonds, trade credits, or sale of equipment.

d) ÌýÌýÌýDepending on the facts and circumstances, the rates of 5% and 15% could, in the case of the U.S., apply to income from shares or other rights, not being debt-claims and any income or distribution treated as income from shares.Ìý

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e)ÌýÌý Applies to interest on bonds, bank deposits etc.

f)ÌýÌýÌý Depending on the specific treaty, this applies to interest on loans which are either, 1) not represented by bearer securities and granted by banking enterprises; or, 2) loans of whatever kind granted by a bank from the other contracting state.

g)ÌýÌý Applies to interest paid to a government agency, political subdivision, local authority or instrumentality of a Contracting State that is not subject to taxation by that State.

h)ÌýÌý Applies to interest paid by banks, authorized financial institutions or insurance companies. Some treaties specify which banks or institutions qualify for treaty benefits.

i)ÌýÌýÌýÌý From 1 March 2010, no withholding tax is levied on interest paid to non-resident companies.

j)ÌýÌýÌýÌý Applies if the beneficial owner is not a bank or an insurance company and the interest is: 1) paid by a bank or, 2) paid by the purchaser of machinery and equipment to the seller in connection with a sale on credit.

k)ÌýÌýÌý Interest derived by a resident or corporation of a Contracting State, from a US trade or business through a permanent establishment, is taxed as effectively connected income and not subject to the general 30% withholding tax at the source of payment.

l)ÌýÌýÌýÌý Domestic withholding rate applies to interest in excess of 9% annually and where the recipient US Corporation has more than 50% interest in the Greek paying company.

m)ÌýÌý The domestic withholding tax rates apply to interest and royalty payments in excess of fair and reasonable compensation.

n) ÌýÌý (Greece) The exemption applies to interest received from sources within the US by a resident or corporation of Greece. It does not apply to interest paid by a US subsidiary corporation to its Greek parent corporation controlling directly or indirectly, more than 50% of the voting power in the paying corporation.

o)ÌýÌý Applies to interest derived from: (i) loans granted by banks and insurance companies; and (ii) bonds or securities that are regularly and substantially traded on a recognized securities market.

Ìýp)Ìý The lower rate applies to interest on long-term loans granted by a bank to finance the purchase of equipment, or the study, installation or supplying of industrial or scientific complexes or public works. The term of such loans varies by treaty.

q)ÌýÌý 0% applies for interest paid between unrelated companies (less than 25% participation).

r)ÌýÌýÌý

s)ÌýÌýÌý (Luxembourg) There is no withholding tax on ordinary interest paid to non-resident companies. However, interest on profit-sharing bonds is subject to the same withholding tax as dividends.

t)ÌýÌýÌý (India) The lower treaty rates apply to interest on loans made or guaranteed by a bank or other financial institution carrying on a bona fide banking or financing business or by an enterprise which holds directly or indirectly at least 10% of the capital of the company paying the interest.

u)ÌýÌý The 0% rate applies under the following circumstances: 1) the interest is beneficially owned by a qualified governmental entity that holds, directly or indirectly, less than 25% of the capital of the payor; 2) the interest is paid with respect to debt obligations guaranteed or insured by a qualified governmental entity; 3) the interest is paid or accrued with respect to a sale on credit of goods, merchandise, or services provided by one enterprise to another enterprise; or 4) the interest is paid or accrued in connection with the sale on credit of industrial, commercial, or scientific equipment.

v)ÌýÌýÌý (Mexico) The withholding rate is 10% for interest paid to a non-resident bank, a financial institution owned by a foreign state or certain limited financial institutions, a non-resident institution that places or invests capital in Mexico, interest relating to securities publicly traded through banks and stock brokerage firms in a country with which Mexico does not have a tax treaty, or interest relating to eligible financial derivatives, provided certain conditions are met. interest paid to registered foreign banks may be subject to a 4.9% rate instead of 10%, provided that the beneficial owner of such interest is a resident of a country with which Mexico has a tax treaty in force. The withholding rate is 4.9% on interest paid in respect to publicly traded securities in Mexico and securities publicly traded abroad through banks and stockbrokerage firms in a country with which Mexico has a tax treaty, and interest paid to non-resident financial entities in which the federal government has a capital interest. The withholding rate is 15%: interest paid to reinsurance companies. The rate is 21% on interest not subject to the 4.9% or 10% rates mentioned above and interest paid to non-resident suppliers financing the acquisition of machinery and equipment. For all other income, the withholding rate is 28%.

w)ÌýÌý (Czech Republic-Brazil) 10% in respect of interest from loans and credits granted by a bank for a period of at least 10 years in connection with the selling of industrial equipment or with the study, the installation or the furnishing of industrial or scientific units, as well as with public works.Ìý

(New Zealand) The payee may elect for approved issuer levy (AIL) to be deducted from the interest received at a rate of 0% if the interest is paid between non-associated parties. If this election is made, the recipient may not be able to claim a foreign tax credit for the amount deducted.

y)ÌýÌýÌý (Italy) Interest payments to non-resident companies are subject to a final withholding tax at the same rates as interest paid to residents. However, no withholding tax applies to interest paid to non-resident companies on: 1) deposit accounts and current accounts with banks and post offices and, 2) bonds issued by the state, banks or listed companies if the beneficial owner is resident in a country with which Italy has an adequate exchange-of-information system. Non-exempt interest, on deposit and current accounts and bonds, is subject to a 27% withholding tax. For bond interest, the rate is reduced to 12.5% if other conditions under the Treaty are satisfied. Other types of interest paid to non-resident companies, including interest on loans, are subject to withholding tax at a 12.5% rate (27% if paid to a resident of a jurisdiction with a preferred tax regime (i.e., low-tax or tax haven jurisdiction).

z)ÌýÌýÌý (Romania) The withholding rate is 0% as long as the other Contracting State, under local law, does not levy withholding tax on interest paid to Romanian residents. Under Romania-Netherlands Treaty, interest is exempt from withholding tax if: 1) interest is paid to a bank, financial institution or insurance company; or, 2) interest paid on a loan made for a period of more than 2 years.

aa)Ìý (Belgium-US) For contingent interest arising in Belgium from related party sales income or dividend / partnership distributions, US residents are taxed under Belgium law at a rate not exceeding 15%. For “contingent interestâ€� arising in the US that does not qualify as portfolio interest under US law, Belgian residents are taxed at a rate not exceeding 15%.

bb) (Brazil) The 25% withholding rate on interest applies to residents of a low-tax jurisdiction. Under Brazilian law, jurisdictions that do not tax income, or which tax income at a maximum rate lower than 20%, are deemed to be low-tax jurisdictions.

cc)Ìý (Canada) As of 1 January 2008, interest paid to an arm’s length non-resident party is exempt from withholding tax. Interest paid to non-arm’s length non-residents remains subject to a 25% withholding tax rate (subject to reduction by any applicable tax treaty). Interest is also exempt from withholding tax if it is payable on various bonds, debentures, notes and mortgages issued or guaranteed by the Canadian government or if issued by provincial governments. The treaty rates shown in the table would apply to non-exempt interest subject to withholding tax.

dd) (Germany) Withholding tax is imposed on interest from convertible bonds, profit-sharing bonds, participation loans, as well as income from the participation of silent partners in a trade or business. The rate is 25% (26.38% including the 5.5% solidarity surcharge). In addition, interest on coupons of bearer bonds not credited to a bank account with a foreign bank (i.e., anonymous over-the-counter transactions) is subject to the same higher withholding tax rate. The withholding tax rate of 25% on regular bank interest for residents does not apply to payments to non-residents.

ee) (India-Iceland) The benefits under the articles for dividends, interest and royalties do not apply if: 1) by reason of special measures the tax imposed on the recipient corporation by its country of residence with respect to the dividends, interest and royalties, is substantially less than the tax generally imposed on corporate profits; and, 2) 25% or more of the capital of the recipient corporation is owned directly or indirectly by one or more persons who are not individual residents of the corporation’s country of residence.

ff)ÌýÌý (India-US) With interest payments arising in India, interest from loans or credit extended or endorsed by the Export Import Bank of the United States and by the EXIM Bank of India is exempt from withholding tax.

gg) (Ireland) Interest payments are exempt from the general 20% withholding tax rate in the following cases: 1) interest on profit-sharing loans (treated as dividends); 2) interest on quoted Eurobonds held in a recognized clearing system or held by a non-resident who has filed a prescribed declaration; 3) interest paid to a company resident in another EU Member State or in a tax treaty country in the ordinary course of the payer’s business; 4) interest paid to a bank carrying on a business in Ireland; 5) interest paid by a resident bank on deposits) to a non-resident company; and, 6) interest paid by SFAZ and IFSC companies.

hh) (Japan) The withholding tax rate on interest on Japanese government bonds (JGBs), municipal bonds, corporate bonds and savings or deposits placed with entities located in Japan is 15%, while interest on loans to a person who uses the loan for operating a business in Japan is 20%.

ii)ÌýÌýÌý (Singapore) The lower rate applies to interest paid to a financial institution in respect of an industrial undertaking.

jj)ÌýÌýÌý (Canada-US) The 0% rate applies to interest paid or credited between unrelated persons on or after January 1, 2008. A 7% rate applies to interest paid or credited between related persons, as defined in the treaty, during the 2008 calendar year. A 4% rate applies to interest paid or credited between related persons during the 2009 calendar year. A 0% rate applies to interest paid or credited between related persons on or after 1 January 2010.

kk)Ìý (Mexico-France). The general rate under the treaty is 15%. However, by virtue of a most-favored nation clause, the general rate is reduced to 5% for interest paid to banks and insurance companies and for interest from quoted bonds, and to 10% in other cases.

ll)ÌýÌýÌý Rate applies in appropriate cases under the EC Interest and Royalties Directive.

mm) The 2009 first-time tax treaty between Canada and Greece entered into force 16 December 2010 and applies as from 1 January 2011. According to the treaty, the rates are reduced from 25% to 10%.

nn) The 2008 treaty between India and Luxembourg entered into force on 9 July 2009 and applies generally as from 1 April 2010 for India (1 January 2010 for Luxembourg). According to the treaty, the rate is reduced to 10%.

oo) Interest may only be taxed by the state of residence of the recipient.

pp) The 2010 treaty between Ireland and Singapore entered into force 8 April 2011 and retroactively applies from 1 January 2011. According to the treaty, the rates are reduced from 20% to 5% in Ireland and from 15% to 5% in Singapore.

qq) The 2007 treaty between Mexico and India entered into force on 1 February 2010.Ìý The treaty applies in Mexico as from 1 January 2011 with a royalty withholding rate of 10%.Ìý The treaty rate applies in India as from 1 April 2011 and once in effect, reduces the rate from 20% to 10% on royalty payments made from India.

rr)ÌýÌý The 2009 treaty between Mexico and South Africa entered into force on 22 July 2010, and applies as from 1 January 2011. ÌýAccording to the treaty, the royalty withholding rate is 10%.Ìý

ss)Ìý The 2008 Second Protocol to the 1982 New Zealand-U.S. treaty entered into force on 12 November 2010 and applies with respect to withholding taxes for amounts paid or credited on or after 1 January 2011. For all other taxes, the protocol will generally have effect as from 1 April in New Zealand and in the U.S. for taxable periods starting on or after 1 January 2011. A 0% withholding tax applies on interest paid to lending or finance businesses, provided the 2% Approved Issuer Levy is paid on New Zealand-source interest; 10% applies in all other cases.

tt) ÌýÌý The rate was increased to 18% from 15% as from 1 January 2011.

uu)Ìý The treaty applies as from 1 April 2011 in Hong Kong and for corporate taxes in the U.K. (as from 6 April 2011 for income and capital taxes in the U.K.). ÌýAccording to the treaty, the reduced rate of 0% (from 20%) is applied as from 1 April 2011 for the payments from U.K. to Hong Kong.Ìý For the payments from Hong Kong to U.K., the rate remains unchanged at 0%.Ìý

vv)Ìý As from 1 January 2011, a flat 16% withholding tax rate replaces the progressive rates applicable on interest paid to nonresident natural persons.Ìý

ww) The treaty calls for reciprocity and Norway currently exempts interest from taxation, resulting in the U.S. applying a zero rate on withholding. A rate may not be imposed in excess of 10% and other exemptions would apply if the 10% rate were imposed.

xx)Ìý The 2009 first-time tax treaty between Greece and Canada entered into force 16 December 2010 and applies as from 1 January 2011.

yy)Ìý (U.S.) A 15% rate applies to interest that is determined with reference to the profits of the issuer or of one of its associated enterprises.

zz)Ìý (U.S.) This rate applies to contingent interest that does not qualify as portfolio interest.Ìý The Internal Revenue Code generally defines contingent interest as any interest if the amount of such interest is determined by reference to: (a) any receipts, sales or other cash flow of the debtor or a related person; (b) any income or profits of the debtor or a related person; (c) any change in value of any property of the debtor or a related person; (d) any dividend, partnership distributions, or similar payments made by the debtor or a related person; or (e) any other type of contingent interest that is identified by the Secretary by regulation, where a denial of the portfolio interest exemption is necessary or appropriate to prevent avoidance of U.S. federal income tax. Section 871(h)(4)(A)(i) and (ii).

aaa) Interest beneficially derived by the following persons is exempt from tax: (i) a bank or other financial institution; and (ii) a resident of the U.S. or Cyprus with respect to debt obligations arising in connection with the sale of property or the performance of services.

bbb) A 15% rate applies to interest that is determined by reference to: (i) receipts, sales, income, profits or other cash flow of the debtor or a related person; (ii) any change in the value of any property of the debtor or a related person or to any dividend; (iii) partnership distribution or similar payment made by the debtor or a related person.

ccc) Depending on the facts and circumstances, the rates of 0%, 5% and 15% could, in the case of the U.S., apply to contingent interest of a type that would not qualify as portfolio interest

ddd) Depending on the facts and circumstances, the rates of 0%, 5% and 15% could, in the case of theÌýÌý U.S., apply to income from debt obligations carrying the right to participate in profits.

eee) (Belgium � Italy) This rate applies if the interest is paid to the Government on loan (excluding bearer instrument).

fff) (Belgium � Japan) This rate applies if the interest is paid on an inter-company loan, if the interest is paid to the Government, Central Bank, and if the interest is paid to a pension fund.

ggg) (Colombia) The withholding tax rate is 15% if the interest is payable on loans with duration of at least one year, 5% if interest paid on loans for infrastructure projects that meet certain criteria (one being a term of 8 years or more), and 0% for the following: (a) interest from financial institutions (including Colombian banks, international financial entities (such as International Monetary Fund and the International Finance Corporation), leasing companies and Colombian specialized financial companies); (b) interest on debt obligations of 6 months or less incurred to import goods and interest of a similar term on bank overdrafts; (c) interest on debt incurred in for exports and other foreign trade transactions; and (d) interest on loans from foreign governmental financial entities in countries with agreements with Colombia.

hhh) (Cyprus) 0%. Subject to the exceptions below, there is no withholding tax on interest paid to nonresidents; 17%. Effective January 1, 2024, a 17% SDC must be withheld from interest payments to a nonresident corporation that is either: (a) registered in a jurisdiction included in the EU list of non-cooperative jurisdictions; or (b) incorporated or registered in such a jurisdictions and not tax resident in a jurisdiction excluded from that list. The 17% withholding tax does not apply to interest paid with respect to securities listed on a recognized stock exchange. (The SDC withholding rate was 30% on interest payments made between December 31, 2022, through December 31, 2023.)

iii) (Czech Republic) A 35% withholding tax is imposed on interest paid to non-residents, subject to the following exceptions: a) 15%. Save where an exemption applies under the EU Interest and Royalties Directive (see below), the withholding rate is 15% on interest paid to recipients resident in an EU Member State; Iceland or Norway; or a country that has signed a tax treaty or a tax information exchange agreement (TIEA) with the Czech Republic, or is a signatory to a multilateral exchange of information agreement to which the Czech Republic is also a signatory; b) 0%. There is an exemption for payments of interest meeting the requirements under the domestic law implementation of the EU Interest and Royalties Directive � broadly, interest paid by a Czech company to an “associated company� (a 25% common shareholding requirement) resident in another EU Member State).This exemption is extended to associated companies resident in Iceland and Norway, and also, under Article 15 of the agreement of October 26, 2004 between the European Union and Switzerland (the “EU Savings Agreement�), to an associated company resident in Switzerland. There is also an exemption for interest paid to certain qualifying EU/EEA pension funds and interest paid on quoted Eurobonds.

jjj) (France) A full exemption from withholding tax on interest may be available under the domestic law implementation of the EU Interest and Royalties Directive, where the paying and recipient companies meet the respective requirements for the application of the exemption.

kkk) (Israel) A full exemption applies if the interest is paid on a listed government bond, paid on a foreign currency public loan, or a foreign currency bank deposit. The 22% rate applies if the interest is paid to a company, and the 25% rate applies if the interest is paid to an individual.

lll) (Israel � Australia) a full exemption is available if the interest is paid to the Government, Central Bank. The 5% rate applies if the interest is paid to a recognized superannuation fund, or a financial institution which is unrelated to and dealing wholly independently with the payer. This rate does not apply if the interest is paid as part of an arrangement involving back-to-back loans or other similar arrangements. The 10% rate applies if the interest is paid to a related person.

mmm) (Israel � Canada) a full exemption is available if the interest is paid to the Government, Central Bank, or if it is paid to an exempt pension fund that is a portfolio shareholder. The 5% rate applies if the interest is paid to a financial institution at an arm’s length basis.

nnn) (Israel � all) An exemption applies if paid to a Government, Central Bank.

ooo) (Israel � Singapore) A full exemption is available if paid to a Government, Central Bank, or a Sovereign Wealth Fund.

ppp) (Israel � U.K.) A full exemption is available if paid on a corporate bond that is traded on stock exchange, if the interest is paid by the Government, Central Bank, if the interest is paid to the Government, Central Bank, or if the interest is paid to a pension scheme. The 5% rate applies if the interest is paid to a bank.

qqq) (Israel � U.S.) A full exemption applies if the interest is paid to the Government; domestic rates apply to any excess inclusion with respect to residual interest in a real estate mortgage investment conduit.

rrr) (Italy � all) A full exemption applies if interest is paid to, or by, the Government.

sss) (Italy � Brazil) A full exemption applies if interest is paid to the Government

ttt) (Italy � Colombia) A full exemption is available if interest is paid by the Government, paid to the Government, Central Bank, or if paid between financial institutions. 5% rate applies if paid to a recognized pension fund, and both the 5% and 10% rates are subject to a most favored nation clause.

uuu) (Italy � Mexico) The 10% rate is subject to a most favored nation clause.

vvv) (Japan � Belgium) A full exemption is available if interest is paid to the Government, Central Bank, a pension fund, or an inter-company loan.

www) (Japan � all ) A full exemption is available if interest is paid to the Government, Central Bank.

xxx) (Japan � Colombia) A full exemption is available if interest is paid to the Government, Central Bank, paid to a bank or financial institution, or to a mandatory pension fund.

yyy) (Japan � France) A full exemption is available if interest is paid to the Government, Central Bank, or if it is paid to a bank, insurance company, securities company.

zzz) (Japan � Germany) Domestic rate applies on interest that is determined by profit participation. This rate also applies if the interest is deductible in the source state

aaaa) (Japan � Iceland) This rate is imposed on interest that is determined by profit participation.

bbbb) (Japan � Netherlands) A full exemption is available if interest is paid to the Government, Central Bank, or if it is paid to a bank, insurance company, securities company, or a pension fund.

cccc) (Japan � Sweden, U.K.) This rate is imposed on interest that is determined by profit participation.

dddd) (Japan � U.S.) The 10% rate is imposed on interest that is determined by profit participation, and domestic rates apply to any excess inclusion with respect to residual interest in a real estate mortgage investment conduit.

eeee) (Luxembourg domestic rate) The 15% rate applies if the interest is paid on a profit-sharing bond.

ffff) (Luxembourg � Belgium) A full exemption is available if the interest is paid on an inter-company loan between related parties or paid on a bond (excluding security representing commercial debt-claim).

gggg) (Luxembourg � Brazil) A full exemption is available if the interest is paid on a government security, bond, or paid to the Government.

hhhh) (Luxembourg � Canada) A full exemption is available if the interest is paid to the Government or to an exempt pension fund.

iiii) (Luxembourg � all) A full exemption is available if the interest is paid to the Government, Central Bank.

jjjj) (Luxembourg � U.S.) 15% is imposed on contingent interest, and domestic rates apply to any excess inclusion with respect to residual interest in a real estate mortgage investment conduit.

llll) (Mexico � Belgium) A full exemption is available if the interest is paid to the Government or to a pension fund. The 5% rate applies if the interest is paid on a bond that is substantially and regularly traded on a recognized securities market, or if the interest is paid to a bank, financial institution, investment bank, savings bank, insurance company.

mmmm) (Mexico � Brazil) A full exemption is available if the interest is paid on a government security, bond, debenture, paid to the Government, Central Bank, or paid to a pension fund.

nnnn) (Mexico � Canada) Domestic rates apply if interest is not paid on an arm’s length basis.

oooo) (Mexico � All) A full exemption is available if interest is paid to the Government, Central Bank.

pppp) (Mexico � France) The general rate under the treaty is 15%. However, by virtue of a most favored nation clause, the rate is reduced to:5%, with respect to interest paid to banks and insurance companies and for interest from quoted bonds. Under the Mexico and United Kingdom treaty, the rate for such interest is 5%; and 10%, in other cases. Under the Mexico and Ireland treaty, the rate is 10%.

qqqq) (Mexico � Italy) The general rate under the treaty is 15%. However, by virtue of a most favored nation clause, the rate is reduced to 10%. Under the Mexico-Portugal treaty, the general rate is 10%

rrrr) (Netherlands � Domestic) 25.8% rate applies if the interest is paid to an affiliated entity in a low-tax jurisdiction.

ssss) (Netherlands � Belgium) An exemption applies if the interest is paid by a bank on long-term deposit (excluding bearer instrument) to an enterprise.

tttt) (Netherlands � India) The rate under the treaty is 10% for interest paid to banking or financial institutions or to an enterprise which holds directly or indirectly at least 10% of the capital of the company paying the interest and 15% in all other cases. However, by virtue of a most favoured nation clause, the general rate is reduced to 10%. Under the Germany and India treaty, the rate is 10%.

uuuu) (New Zealand � Canada) The 0% rate applies where the interest is paid to a financial institution that is unrelated to and dealing wholly independently with the payer.

vvvv) (Norway Domestic) 15% rate applies if the interest is paid to a low-tax jurisdiction.

wwww) This rate applies if the interest is paid to a corporation or individual for an operation carried out outsideÌýSingapore. Otherwise, rate is 17% and 24% respectively.

a)ÌýÌýÌý Under domestic law, there is no withholding tax on royalties. However, a nonresident recipient of royalties is deemed to have a PE in Sweden in respect of royalties received. Thus, the recipient would be taxed in Sweden on the net royalty income (i.e. the gross royalty less expenses related to the royalty) at the ordinary corporate income tax rate (26.3%).

b)ÌýÌýÌý The 0% rate applies if the Netherlands does not levy a withholding tax on royalties paid to a resident of Romania.

c)ÌýÌýÌý Payments of any kind made as a consideration for the use of or the right to use copyrights of motion picture films or films or tapes used for radio or television broadcasting are not covered under “Royaltiesâ€� article.Ìý Instead, they are covered under the “Business profitsâ€� article and generally are not subject to withholding tax unless they are derived from a permanent establishment in the paying country.Ìý

d)ÌýÌýÌý As from 1 January 2011, a flat 16% withholding tax rate replaces the progressive rates applicable on royalties paid to nonresident natural persons.

e)ÌýÌýÌý (Iceland) Nonresident companies: 22%. The withholding tax rate for royalties paid to nonresident companies is 22%; nonresident individuals: 22%. The withholding tax rate for royalties paid to nonresident individuals is 22%. Municipal income tax is also levied on royalties paid to nonresident individuals at an average rate (currently 14.44% (2018)).f)ÌýÌýÌýÌýÌý A 5% rate may be imposed on the gross amount of any payment of any kind received by a resident of the other Contracting State as a consideration for the use of, or the right to use, motion picture films (other than films for exhibition on television).

g)ÌýÌýÌý Film royalties are not exempt; however, no specific rate is provided under the treaty.

h)ÌýÌýÌý Under Indian domestic law, the withholding tax rate for royalties paid outside of India is 25%, plus a 2% surcharge

ÌýÌýÌýÌýÌýÌý (if payment exceeds INR 10Ìýmillion) and a 5% CESS, provided certain conditions are satisfied. The withholding tax is, therefore, 26.265%/27.037%.

i)ÌýÌýÌýÌý The withholding tax on royalties paid to nonresident corporations is 15% (15.825%, including the solidarity surcharge). The rate is 30% (31.65%, including the solidarity surcharge) if paid to nonresident natural persons. The rate is 0% if the royalties qualify under the EC Interest and Royalties Directive.

j)ÌýÌýÌýÌý Applicable to royalties from films other than films shown on TV.

k)ÌýÌýÌý The domestic withholding tax rate of 25% apply to interest and royalty payments in excess of fair and reasonable compensation.

l)ÌýÌýÌýÌý The general rate under the treaty is 20% on royalties. However, by virtue of a most-favoured-nation clause (Protocol Para. 7), the rate is reduced to 10% (Under the treaty between India and Germany, for example, the rate is currently 10%).

m)ÌýÌý If the royalty is paid to an overseas associate and the intellectual property that generates the royalty has been wholly or partly owned by a person carrying on business in Hong Kong, 100% of the royalty payment would be deemed to be assessable. As the current corporate tax rate in Hong Kong is 16.5%, the effective tax rate on the royalty payment would be 16.5%. In any other situation, 30% of the royalty payment would be deemed to be assessable. This will give rise to an effective tax rate of 4.95% (i.e., 30% x 16.5%).

n)ÌýÌýÌý Royalties from artistic and literary copyrights, with the exception of those relating to software, are exempt from withholding tax.

o)ÌýÌýÌý The rate is 4.4% for royalties on cinematographic or television films.Ìý

p)ÌýÌýÌý Royalties paid to nonresidents for the use of rights outside Cyprus are exempt from withholding tax. Where royalties are earned on rights used within Cyprus, there is a withholding tax rate of 5% form film and TV rights.

q)ÌýÌýÌý The rate on royalty payments is increased to 25% if the recipient is resident in a jurisdiction that is deemed to be a low tax jurisdiction.

r)ÌýÌýÌý The 2008 Second protocol to the 1982 U.S. â€� New Zealand entered into force on 12 November 2010 and applies with respect to withholding taxes for amounts paid or credited on or after 1 January 2011.Ìý The royalty withholding tax rate is reduced from 10% to 5%.Ìý

s)ÌýÌýÌý The 28% rate applies to royalties paid for the use of patents and trademarks; the 25% rate applies to all other royalties and technical assistance; the 40% rate applies to royalties paid to residents of countries with a preferential tax regime.

t)ÌýÌýÌýÌý The Czech Republic has been granted a transition period to fully apply the EC Interest and Royalties Directive with respect to royalties. The country may levy a withholding tax until 30 June 2011; thereafter, such payments will be exempt provided the requirements for application of the Directive are met.

u)ÌýÌýÌý The 10% rate applies provided the income is not derived by the nonresident through its operations carried out in or from Singapore. Where operations are carried out in or from Singapore, royalty income will be taxed at the prevailing corporate tax rate.

v)ÌýÌýÌý For payments made after 23 April 2010, the statutory withholding tax on royalties paid to a foreign entity without a PE in Greece is increased from 20% to 25%, unless the rate is reduced under an applicable tax treaty. The EC Interest and Royalties Directive allows Greece to continue to apply a 10% withholding tax until 30 June 2009, and 5% until 30 June 2013.

w)ÌýÌý The new double tax arrangement between China and Hong Kong came into effect on 8 December 2006 and provides for a 7% rate (for income arising in Hong Kong for the year of assessment 2007/08 onward). The lower domestic effective rate of 4.95% would apply to unaffiliated nonresidents receiving payments from Hong Kong payors.

x)ÌýÌýÌý According to the treaty, as from 1 April 2011, the payments from Hong Kong to U.K. are subject to the reduced rate of 3% from 4.95%.Ìý For the payments from U.K. to Hong Kong, the rate is reduced to 3% from 20% as from 6 April 2011.

y)ÌýÌýÌý The 10% rate applies to copyrights royalties (including films, etc.). The 20% rate applies to trademark royalties (the rate was reduced from 25% to 20% by a protocol that entered into force on 1 January 2008).

z)ÌýÌýÌý The 0% rate applies to (a) copyright royalties and other like payments in respect of the production or reproduction of any literary, dramatic, musical or other artistic work (but not including royalties in respect of motion picture films or royalties in respect film or videotape or other means of reproduction for use in connection with television broadcasting). Otherwise, the rate is 10%.

aa)Ìý The 2010 treaty between the U.K. and Germany to replace the 1964 treaty entered into effect on 30 December 2010 and applies in both countries to taxes withheld at source as from 1 January 2011 (with general application from that date in Germany and from 1 April 2011 (corporate taxes) and 6 April 2011 (income and capital gains) in the U.K.).Ìý Under the new treaty, the royalty withholding tax rate remains at 0%.

bb)Ìý The 15% rate applies to trademark royalties, and the 10% rate applies in all other cases.

cc)Ìý The rate is 15% for film and broadcasting royalties and copyright royalties on literary, artistic and scientific works; 25% on trademark royalties; and 12.5% in all other cases. Under domestic law, the withholding tax on trademark royalties is 15% so the domestic rate, rather than the treaty rate, applies.

dd)Ìý Under the Belgium-Czech Republic treaty, a 10% rate applies to royalties paid for the use of, or the right to use, a copyright of literary, artistic or scientific work, including cinematograph films and films or tapes for television or radio broadcasting, any software, patent, trademark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience. However, under the protocol to the Belgium-Czech Republic treaty, if the Czech Republic concludes a treaty that provides a lower rate for royalties, that rate will apply to Belgium. The new Czech treaty with Slovak Republic does provide for a lower rate of 0% on copyright royalties, including film, etc. So that rate also applies to Belgium.

ee)Ìý The 0% rate applies to royalties paid in respect of copyrights; otherwise the rate is 10%.

ff)ÌýÌý The 0% rate applies to copyright royalties, except royalties concerning cinematograph films and films or tapes for television broadcasting. Otherwise, the rate is 10%.

gg)Ìý The domestic rate applies to motion picture film royalties.

hh)Ìý A 30% withholding tax is imposed on royalty payments to nonresidents, which is generally only applied to 75% of the gross amount, giving rise to an effective rate of 22.5%.

ii)ÌýÌýÌý The rate for patent royalties and annual payments is 10%. In all other cases, royalties are exempt from tax.

jj)ÌýÌýÌý While royalties are generally exempt, the following items are subject to a rate not to exceed 5%: trademarks and any information concerning industrial, commercial or scientific experience provided in connection with a rental or franchise agreement that includes rights to use a trademark, or (as previously excluded from reduced rates) a motion picture film or work on film or videotape or other means of reproduction for use in connection with television.

kk)Ìý The new tax treaty between New Zealand and Australia entered into force on 19 March 2010 with the new withholding tax rates applying as from 1 May 2010. According to the treaty, the rates are reduced to 5% from 10%.

ll)ÌýÌýÌý The 0% rate applies if the conditions under EC Interest and Royalties Directive are met.

mm) Romania levies a 16% withholding tax on royalties paid to nonresident companies, unless an applicable tax treaty provides for a lower rate. Under transitional rules in the EC Interest and Royalties Directive, Romania is authorized not to apply the exemption from withholding tax until 31 December 2010.

nn)Ìý Royalties derived by a resident or corporation of a Contracting State from a trade or business through a permanent establishment in the US are governed by the business profits provision and not subject to the withholding of US tax at source.

oo)Ìý The 2009 first-time tax treaty between Canada and Greece entered into force 16 December 2010 and applies as from 1 January 2011.
Royalties are subject to withholding at a rate of 10%, except in the case of exempt copyright royalties and other like payments in respect of the production or reproduction of any cultural or artistic work (but not including royalties in respect of motion picture films nor royalties in respect of works on film or videotape or other means of reproduction for use in connection with television broadcasting).

pp)Ìý The 2007 treaty between Mexico and India entered into force on 1 February 2010 and applies in Mexico as from 1 January 2011 (in India as from 1 April 2011).Ìý According to the treaty, the rate is reduced from 40% to 10% in Mexico.Ìý The rate remains unchanged in India.

qq)Ìý The 2009 treaty between Mexico and South Africa entered into force on 22 July 2010, and applies as from 1 January 2011.Ìý The rate is reduced from 40% to10% in Mexico.Ìý In South Africa, the rate is reduced from 12% to 10%.

rr)ÌýÌý The 2009 treaty and protocol between New Zealand and Singapore entered into force on 12 August 2010. The treaty, which replaces the existing treaty dating from 1973, generally applies in New Zealand as from 1 October 2010 for withholding taxes and from 1 April 2011 for other taxes. The royalty withholding tax rate is reduced from 15% to 5%.Ìý However, the treaty rate will apply as from 1 January 2012 in Singapore.

ss)Ìý Copyright royalties for literary, artistic or scientific work, including film and other means of image or sound reproduction, are exempt; otherwise, the rate is 10%.

tt)ÌýÌýÌý The 2010 first-time treaty between Singapore and Ireland entered into force 8 April 2011 and retroactively applies from 1 January 2011.Ìý In Ireland, the rate is reduced to from 20% to 5%.Ìý In Singapore, the rate is reduced from 10% to 5%.Ìý

uu)

vv)Ìý Payments of any kind made as a consideration for the use of or the right to use cinematographic films, or works on film, tape, or other means of reproduction for use in radio or television broadcasting are not covered under “Royaltiesâ€� article.Ìý Instead, they are covered under the “Business profitsâ€� article and generally are not subject to withholding tax unless they are derived from a permanent establishment in the paying country.

ww) Payments of any kind made as a consideration for the use of or the right to use motion pictures or works on film, tape or other means of reproduction used for radio or television broadcasting are not covered under “Royaltiesâ€� article.Ìý Instead, they are covered under the “Business profitsâ€� article and generally are not subject to withholding tax unless they are derived from a permanent establishment in the paying country.

xx) (Czech Republic) A 35% withholding tax is imposed on royalties paid to non-residents, subject to the following exceptions: a) 15%. Save where an exemption applies under the EU Interest and Royalties Directive (see below), a 15% withholding tax is imposed on royalties paid to recipients resident in an EU Member State; Iceland or Norway; or a country that has signed a tax treaty or a tax information exchange agreement (TIEA) with the Czech Republic, or is a signatory to a multilateral exchange of information agreement to which the Czech Republic is also a signatory; b) 0%. There is an exemption on payments of royalties meeting the requirements under the domestic law implementation of the EU Interest and Royalties Directive � broadly, royalties paid by a Czech company to an “associated company� (a 25 percent common shareholding requirement) resident in another EU Member State). This exemption is extended to associated companies resident in Iceland and Norway, and also, under Article 15 of the agreement of October 26, 2004 between the European Union and Switzerland (the “EU Savings Agreement�), to an associated company resident in Switzerland.

yy) (Japan) The 10% rate applies to “industrial royalties.� A 5% rate applies to “cultural royalties.� Industrial royalties are defined as payments for: (a) the use of, or the right to use, any patent, trademark, design or model, plan, secret formula or process; (b) the use of, or the right to use, industrial, commercial or scientific equipment; or (c) information concerning industrial, commercial or scientific experience. Cultural royalties are defined as payments for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films and films or tapes for radio or television broadcasting.

zz) (France) 25%. Royalties paid to a nonresident company or a nonresident individual are subject to a 25% withholding tax rate (this withholding tax is final), subject to the exceptions below. The withholding tax rate for royalties was 26.5% in 2021. 10% for profits derived from certain intellectual property (IP) rights are subject to a 10% withholding tax rate; 0% for payments of royalties meeting the requirements under France's implementation of the EU Interest and Royalties Directive (broadly, royalties paid by a French company to an “associated company� resident in another EU Member State) are exempt from withholding tax; royalties paid by a French company to an associated Swiss company may also be exempt under EU Savings Agreement, Art. 15, subject to essentially the same conditions as those that apply under the EU Interest and Royalties Directive; 75% for royalties paid to a beneficiary (corporate or individual) or an account located in a listed “non-cooperative State or territory� (NCST) are subject to a 75% withholding tax rate unless the payer can prove that the payments do not have a tax avoidance motive.