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Treaty between Greece and Iceland enters into force

The income tax treaty and protocol between Greece and Iceland, signed on 7 July 2006, entered into force on 7 August 2008. The treaty generally applies from 1 January 2009.

Treaty between Greece and Iceland – details

Details of the income tax treaty betweenGreece and Iceland , signed on 7 July 2006, have become available. The treaty was concluded in Icelandic, Greek and English languages, each text having equal authenticity. In the case of divergence, however, the English text prevails. The treaty generally follows the OECD Model Convention.

The maximum rates of withholding tax are:

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15% in general, but 5% if the beneficial owner is a company (other than a partnership) which holds directly at least 25% of the capital of the company paying the dividends;

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8% on interest subject to the exceptions for interest exempted from withholding if paid to the government, a political or administrative subdivision or a local authority of the withholding state, or if it is paid to the same kind of entities of the other state, or an institution or body (including a financial institution) wholly owned by that other state; and

-   10% on royalties.   

Deviations from the OECD Model include:

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Art. 5 (Permanent establishment) provides that a building site, construction or assembly project and connected activities, inclusive planning or supervising, constitute PE if last for more than 9 months; and

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Art. 5 of the treaty provides that a person resident in one state, carrying on activities in connection with preliminary surveys, exploration, extraction or exploitation of natural resources situated in the other state, shall shall be deemed to be carrying on in respect of those activities a business in that other state through a PE situated in that other state when the activities are carried on for a period or periods exceeding 30 days in any 12-month period. The estimation of the period is subject to specific rules in case of related enterprises carrying out the same activities.

Both states generally provide for the ordinary credit to avoid double taxation.

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