Debt securities - Double Taxation Treaties concluded by Japan and currently in force

09.02.2017

Note: Clearstream Banking provides these rates for information purposes only and does not assume liability in any case of error, omission or consequential damages. The rate as prescribed in the DTT may differ depending on the status of the beneficial owner. Please refer to the actual DTT or your tax advisor for further information.

The standard rate of withholding tax on interest is 15.315% before any refund.

Country

Rate prescribed
by the DTT -
Interest (%)

Tax refund
available (%)

Australia

10

5.315

Austria

10

5.315

Azerbaijan

10

5.315

Bangladesh

10

5.315

Belarus

10

5.315

Belgium

10

5.315

Brazil

12.5

2.815

Brunei

10

5.315

Bulgaria

10

5.315

Canada

10

5.315

Chile a15/40.315/11.315

China

10

5.315

Czech Republic

10

5.315

Denmark

10

5.315

Finland

10

5.315

France

10

5.315

Georgia

10

5.315

Germany b

0

15.315

Hong Kong

10

5.315

Hungary

10

5.315

India

10

5.315

Indonesia

10

5.315

Ireland

10

5.315

Israel

10

5.315

Italy

10

5.315

Kazakhstan

10

5.315

Kuwait

10

5.315

Kyrgyz Republic

10

5.315

Luxembourg

10

5.315

Malaysia

10

5.315

Mexico

15

0.315

Netherlands

10

5.315

New Zealand

10

5.315

Norway

10

5.315

Pakistan

10

5.315

Philippines

10

5.315

Poland

10

5.315

Portugal

10

5.315

Qatar e

0/10

15.315/5.315

Republic of Armenia

10

5.315

Republic of Moldavia

10

5.315

Romania

10

5.315

Russia

10

5.315

Saudi Arabia

10

5.315

Singapore

10

5.315

Slovakia

10

5.315

South Africa

10

5.315

South Korea

10

5.315

Spain

10

5.315

Sri Lanka d

0

15.315

Sultanate of Oman

10

5.315

Sweden

0

15.315

Switzerland

10

5.315

Taiwan b

10

5.315

Tajikistan

10

5.315

Thailand

25

0

Turkey

15

0.315

Turkmenistan

10

5.315

Ukraine

10

5.315

United Arab Emirates e

10/0

5.315/15.315

United Kingdom

0

15.315

United States of America

10

5.315

Uzbekistan

10

5.315

Vietnam

10

5.315

Zambia

10

5.315

a. For Chile, the standard rate is 15%. However, the rate prescribed for the following eligible financial institutions is 4%:

  • A bank;
  • An insurance company;
  • A company substantially deriving its gross income from the active and regular conduct of a lending or finance business involving transactions with unrelated persons;
  • A company that sold machinery or equipment, where the interest is paid with respect to indebtedness arising as part of the sale on credit of such machinery or equipment;
  • Any other company, provided that in the three taxable years preceding the taxable year in which the interest is paid, the enterprise derives more than 50 per cent of its liabilities from the issuance of bonds in the financial markets or from taking deposits at interest, and more than 50 per cent of the assets of the enterprise consist of debt-claims against unrelated persons.

b. Effective as from 1 January 2017.

c. For Qatar, the standard rate is 10%. However, the rate prescribed for the following eligible entities is 0%:

  • A bank, an insurance company, a securities dealer, or other non-financial institution or enterprise that satisfies specified asset/liability tests; or 
  • A pension fund (or scheme), subject to conditions (for example, not derived, directly or indirectly, from the carrying on of a business by that pension fund, as per the treaty with the Netherlands).

d. Only applicable to banks.
e. The following entities should be deemed as residents in UAE defined in Article 4, Paragraph 1 as at 24 December 2014. In other words, any other entities not listed below are not currently able to gain tax benefits under the DTT.

The rate prescribed for the following entities is 10%:

  • Pension funds
  • Mudabala Development Company.

The rate prescribed for the following entities is 0%:

  • Government;
  • Political subdivision;
  • Local authority;
  • Central Bank of the United Arab Emirates;
  • Abu Dhabi Investment Authority;
  • International Petroleum Investment Company;
  • Abu Dhabi Investment Council;
  • Investment Corporation of Dubai;
  • such other similar institution the capital of which is wholly owned by the Government of UAE including a political subdivision/local authority as may be agreed upon from time to time between the Governments of the Contracting States through an exchange of diplomatic notes.