The maximum rates of withholding tax are:
15% on dividends in general and 0% if the beneficial owner is a company (other than a partnership) that holds directly at least 10% of the capital of the company paying the dividends;
|-||0% on interest; and|
|-||10% on royalties in general (including software) and 5% on payments for the use of, or the right to use, industrial, commercial or scientific equipment. Artistic and literary copyrights, with the exception of those relating to software, are exempt.|
With regard to the avoidance of double taxation (Art. 22), both states generally provide for the ordinary credit method. In some cases, however, the exemption with progression method is used.
The treaty makes no specific reference to special tax regimes in either state and it is assumed that it applies to entities qualifying for any such regimes.
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