Equities - Double Taxation Treaties concluded by Japan and currently in force

05.02.2020

Note: Clearstream Banking provides these rates for information purposes only and does not guarantee that this information is correct, complete and accurate. Clearstream Banking does not assume liability for any damages, direct or indirect, that may arise from the reliance on or the use of this information. The rate as prescribed in the DTT assumes that the beneficial owner does not hold a substantial percentage of the share capital of the company paying the dividend. Different rates may apply for substantial holdings. Please refer to the actual DTT or your tax advisor for further information.

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

Country

Rate prescribed
by the DTT -
Dividends (%)

Tax refund
available (%)

Australia

10

5.315

Austria

10

5.315

Bangladesh

15

0.315

Belarus

15

0.315

Belgium

10

5.315

Brazil

12.5

2.815

Brunei

10

5.315

Bulgaria

15

0.315

Canada

15

0.315

Chile a0/1515.315/0.315

China

10

5.315

Croatia510.315

Czech Republic

15

0.315

Denmark b

0/15

15.315/0.315

Egypt

15

0.315

Estonia b0/1015.315/5.315
Ecuador510.315

Finland

15

0.315

France

10

5.315

Georgia

15

0.315

Germany c

15/15.315

0.315/0

Hong Kong

10

5.315

Hungary

10

5.315

Iceland b0/1515.315/0.315

India

10

5.315

Indonesia

15

0.315

Ireland

15

0.315

Israel

15

0.315

Italy

15

0.315

Kazakhstan

15

0.315

Kuwait

10

5.315

Kyrgyz Republic

15

0.315

Latvia b0/10 d15.315/5.315
Lithuania b0/10 d15.315/5.315

Luxembourg

15

0.315

Malaysia

15

0.315

Mexico

15

0.315

Netherlands

10

5.315

New Zealand

15

0.315

Norway

15

0.315

Pakistan

10

5.315

Philippines

15

0.315

Poland

10

5.315

Portugal

10

5.315

Qatar

10

5.315

Republic of Armenia

15

0.315

Republic of Moldava

15

0.315

Romania

10

5.315

Russia

10

5.315

Saudi Arabia

10

5.315

Singapore

15

0.315

Slovakia

15

0.315

Slovenia e5 /10 ​f10.315/5.315

South Africa

15

0.315

South Korea

15

0.315

Spain

15

0.315

Sri Lanka

20

0

Sultanate of Oman

10

5.315

Sweden

10

5.315

Switzerland

10

5.315

Taiwan 

10

5.315

Tajikistan

15

0.315

Thailand g

-

-

Turkey

15

0.315

Turkmenistan

15

0.315

Ukraine

15

0.315

United Arab Emirates h

10

5.315

United Kingdom

10

5.315

United States of America

10

5.315

Uzbekistan

15

0.315

Vietnam

10

5.315

Zambia

0

15.315

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a. For Chile, the standard rate is 15%. Tax exemption is granted to eligible pension funds if the necessary documentation is submitted.

b. The 0% rate applies if dividends are paid by a company that is entitled to a deduction for dividends paid to its beneficiaries in computing its taxable income in Japan where the company paying the dividends is a resident (for example REITs).

c. Effective as from 1 January 2017. 15% is only applicable to dividends from Japanese Listed Equities and ETFs. Dividends from Japanese REITs are subject to the default tax rate (that is, 15.315%), the DTT cannot be invoked as a REIT is not a company which is entitled to a deduction for dividends paid to its beneficiaries in computing its taxable income (as per the DTT Article 4-(a)-(i)).

d. 0% if the beneficial owner is a person other than an individual.

e. The 5% rate applies if dividends are paid by a company that is entitled to a deduction for dividends paid to its beneficiaries in computing its taxable income in Japan where the company paying the dividends is a resident (for example REITs).

f. The 10% rate applies if dividends are paid by a company that is entitled to a deduction for dividends or is subject to tax at a reduced rate if it distributes its profits.

g. For Thailand, the rate prescribed by the DTT-Dividends is:

  • 15% for a company holding at least 25% of the voting shares for more than six months prior to the record date, and dividend is paid by a corporation engaging in industrial business;
  • 20% for a company holding at least 25% of the voting shares for more than six months prior to the record date.

   No standard rate is available.

h. 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:

  • Central Bank of the United Arab Emirates;
  • Abu Dhabi Investment Authority;
  • International Petroleum Investment Company;
  • Abu Dhabi Investment Council;
  • Investment Corporation of Dubai;
  • Mubadala Development Company;
  • Eligible pension funds established in the UAE.