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Sweden

8 October 1980

0 or 10

0

5 or 0

Switzerland

23 December 1997

5 or 15

10 or 0

5 or 0

Syria

27 February 2010

5

10

12

Tunisia

25 October 1991

15 or 10

12 or 0

5 or15

Turkey

2 December 1999

5 or 10

10 or 0

10

Turkmenistan

26 June 1998

10

10 or 0

10

Ukraine

22 November 1996

10

10

10

United Kingdom

20 December 1991

5 or 15

0

10 or 0

United States

30 December 1993

5 or 15

0

10 or 0

Uzbekistan

17 October 2003

10

10

10

Vietnam

29 July 2009

5 or 10

10 or 0

5 or 10 or 15

Treaty country

TABLE 15 - Continued

Valid from

Maximum tax rate on gross amount from Slovakia into the treaty country

Dividends A)

Interest

Royalties

*

** A)

The CMEA treaties. The domestic rate applies to individuals; there is no reduction under the treaty. To be signed by Egypt A distribution of profit after tax in the form of dividends is in general not subject to withholding tax unless the distributed profit was derived prior to 1 January 2004, when rate of 19% would apply. Dividends paid after 1 April 2004 from a Slovak subsidiary to its EU Parent Company are in any event not subject to withholding tax, although these dividends may relate to the distribution of profits earned before 1 January 2004. The receiving (EU parent) company needs to possess a direct shareholding of at least 25% at the time of distribution. Dividends paid to a non EU parent in respect of profits derived prior to 1 January 2004 are subject to withholding tax at 19%, unless a double taxation treaty applies.

88

©2010 KPMG Slovensko spol. s r.o. , a Slovak limited liability company and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved.

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