n Without Prejudice - Might dividends tax be unlawful under certain double tax agreements? : tax

Volume 15, Issue 4
  • ISSN : 1681-178X



It is now well understood that dividends paid to all nonresidents are subject to dividends tax at the rate of 15%, unless reduced in terms of a particular double tax agreement (DTA). (There are still a couple of DTAs that provide for a zero withholding tax on dividends but their days are numbered, and the lowest rate of withholding tax will be 5% where there is a so-called substantial holding - typically at least 10%, depending upon the DTA concerned.)

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