Withholding tax rates
1 The rates in this column apply if the holding is at least the indicated percent-
age of the German company’s capital or voting power and in general only if
a corporation resident in the other country holds the capital or voting rights.
Beyond the minimum percentage of the holding the DTT may require further
conditions to be met, in order to apply the reduced withholding tax rate (for
example minimum amounts of the holding in euro or currency equivalent or
minimum holding periods).
2 Upon request dividend payments to qualifying EU companies are exempt
from withholding tax (see chapter 6.2.2.5).
3 Upon request interest and royalty payments to qualifying EU companies are
exempt from withholding tax (see chapter 6.2.6).
4 Germany and China concluded a new Double Tax Treaty on 28 March 2014.
The new treaty will become effective after ratifcation and will replace the
existing treaty.
5 Complete elimination of taxation at the source on cross border dividend dis-
tributions, provided the recipient company holds at least 80% of the voting
rights in the distributing company and meets one of the requirements listed
in Article 28 Tax Treaty between Germany and the United States.
6 On 21 August 2014 Germany and Israel concluded a new Double Tax Treaty.
The new treaty has not yet entered into force. In order to become effective
it requires ratifcation.
7 On 17 December 2015 Germany and Japan concluded a new Double Tax
Treaty. The new treaty has not yet entered into force. In order to become
effective it requires ratifcation.
8 On 12 November 2015 Germany and Australia signed a new Double Tax
Treaty. The new treaty has not yet entered into force. In order to become
effective it requires ratifcation.
9 On 9 September 2008 Germany and South Africa signed a new Double Tax
Treaty. The new treaty has not yet entered into force. In order to become
effective it requires ratifcation.
EU Forecast
euf:ba.18g:190/nws-01