中国与其它国家税收协定涉及的股息、利息、特许权使用一览表
来源：安永会计师事务所
日期：2018.11.30
Country（国家）
Dividends（股息）
Interest（利息）
Royalties（特许权使用费）
Albania
10
10
10
Algeria
5/10
(a)
7
10
Armenia
5/10
(a)
10
10
Australia
10
10
10
Austria
7/10
(d)
7/10
(h)
6/10
(i)
Azerbaijan
10
10
10
Bahrain
10
10
10
Bangladesh
10
10
10
Barbados
5/10
(a)
10
10
Belarus
10
10
10
Belgium
5/10
(f)
10
7
Brazil
10
10
10
Brunei Darussalam
5
10
10
Bulgaria
10
10
7/10
(k)
Canada
10
10
10
Chile
10
4/10
(t)
2/10
(u)
Croatia
5
10
10
Cuba
5/10
(a)
7.5
5
Cyprus
10
10
10
Czechoslovakia (m)
10
10
10
Czech Republic
5/10
(a)
7.5
10
Denmark
5/10
(a)
10
7/10
(j)
Ecuador (r)
5
10
10
Egypt
8
10
8
Estonia
5/10
(a)
10
10
Ethiopia
5
7
5
Finland
5/10
(a)
10
10
(j)
France
5/10
(a)
10
10
Georgia
0/5/10
(e)
10
5
Germany
5/10/15
(p)
10
6/10
(i)
Greece
5/10
(a)
10
10
Hong Kong SAR
5/10
(a)
7
5/7
(s)
Hungary
10
10
10
Iceland
5/10
(a)
10
7/10
(j)
India
10
10
10
Indonesia
10
10
10
Ireland
5/10
(c)
10
6/10
(i)
Iran
10
10
10
Israel
10
7/10
(h)
7/10
(j)
Italy
10
10
7/10
(j)
Jamaica
5
7.5
10
Japan
10
10
10
Kazakhstan
10
10
10
Korea (South)
5/10
(a)
10
10
Kuwait
5
5
10
Kyrgyzstan
10
10
10
Laos
5
10
10
Latvia
5/10
(a)
10
7
Lithuania
5/10
(a)
10
10
Luxembourg
5/10
(a)
10
6/10
(i)
Macau SAR
5/10
(a)
7
5/7
(s)
Macedonia
5
10
10
Malaysia
10
10
10
Malta
5/10
(a)
10
7/10
(j)
Mauritius
5
10
10
Mexico
5
10
10
Moldova
5/10
(a)
10
10
Mongolia
5
10
10
Morocco
10
10
10
Nepal
10
10
10
Netherlands
5/10
(a)
10
6/10
(i)
New Zealand
10
10
10
Nigeria
7.5
7.5
7.5
Norway
10
10
10
Oman
5
10
10
Pakistan
10
10
10
Papua New Guinea
10
10
10
Philippines
10
10
10
Poland
10
10
7/10
(j)
Portugal
10
10
10
Qatar
10
10
10
Romania (q)
3
3
3
Russian Federation
5/10
(v)
0
6
Saudi Arabia
5
10
10
Seychelles
5
10
10
Singapore
5/10
(a)
7/10
(h)
6/10
(i)
Slovenia
5
10
10
South Africa
5
10
7/10
(j)
Spain
10
10
6/10
(i)
Sri Lanka
10
10
10
Sudan
5
10
10
Sweden
5/10
(a)
10
7/10
(j)
Switzerland
5/10
(a)
10
9
Syria
5/10
(a)
10
10
Tajikistan
5/10
(a)
8
8
Thailand
10
10
10
Trinidad and Tobago
5/10
(a)
10
10
Tunisia
8
10
5/10
(l)
Turkey
10
10
10
Turkmenistan
5/10
(a)
10
10
Ukraine
5/10
(a)
10
10
United Arab Emirates
7
7
10
United Kingdom
5/10
(a)
10
6/10
(i)
United States
10
10
7/10
(j)
Uzbekistan
10
10
10
Venezuela
5/10
(b)
5/10
(g)
10
Vietnam
10
10
10
Yugoslavia (o)
5
10
10
Yugoslavia (former) (n)
10
10
10
Zambia
5
10
5
Zimbabwe
2.5/7.5
(w)
7.5
7.5
Non-treaty jurisdictions
10
10
10
(a) The 5% rate applies if the beneficial owner of the dividends is a company that holds directly at least 25% of the capital of the company paying the dividends. The 10% rate applies to other dividends.
(b) The 5% rate applies if the beneficial owner of the dividends is a company that holds directly at least 10% of the capital of the company paying the dividends. The 10% rate applies to other dividends.
(c) The 5% rate applies if the beneficial owner of the dividends is a company that holds directly at least 25% of the voting shares of the company paying the dividends. The 10% rate applies to other dividends.
(d) The 7% rate applies if the beneficial owner of the dividends is a company that holds directly at least 25% of the voting shares of the company paying the dividends. The 10% rate applies to other dividends.
(e) The 0% rate applies if the beneficial owner of the dividends is a company that holds directly or indirectly at least 50% of the capital of the company paying the dividends and that has invested more than EUR2 million in the capital of the company paying the dividends. The 5% rate applies if the beneficial owner of the dividends is a company that holds directly or indirectly at least 10% of the capital of the company paying the dividends and that has invested more than EUR100,000 in the capital of the company paying the dividends. The 10% rate applies to other dividends.
(f) The 5% rate applies if the beneficial owner of the dividends is a company that, before the moment of the payment of the dividends, directly held for an uninterrupted period of at least 12 months at least 25% of the capital of the company paying the dividends. The 10% rate applies to other dividends.
(g) The 5% rate applies to interest paid to banks. The 10% rate applies to other interest payments.
(h) The 7% rate applies to interest paid to banks or financial institutions. The 10% rate applies to other interest payments.
(i) Payments for the use of industrial, commercial or scientific equipment are taxed on the basis of 60% of the gross payments. Consequently, the effective rate for such payments is 6%.
(j) Payments for the use of industrial, commercial or scientific equipment are taxed on the basis of 70% of the gross payments. Consequently, the effective rate for such payments is 7%.
(k) The 7% rate applies to royalties paid for the use of, or the right to use, industrial, commercial and scientific equipment. The 10% rate applies to other royalties.
(l) The 5% rate applies to royalties paid for technical or economic studies or for technical assistance. The 10% rate applies to royalties paid for the use of, or the right to use, copyrights of literary, artistic or scientific works including cinematographic films, films or tapes for radio or television broadcasting, patents, trademarks, designs or models, plans, or secret formulas or processes, or for the use of, or the right to use, industrial, commercial or scientific experience.
(m) China is honoring the Czechoslovakia treaty with respect to the Slovak Republic until a new treaty is signed.
(n) After the partition of the former Yugoslavia, China is honoring the double tax treaty with the former Yugoslavia with respect to Bosnia and Herzegovina.
(o) China entered into a treaty with the Federal Republic of Yugoslavia. It has been indicated that China considers Serbia to have inherited the Yugoslavia treaty and that China is also honoring the treaty with respect to Montenegro. However, it is suggested that taxpayers check with the relevant tax authorities before relying on this treaty.
(p) The 5% rate applies if the beneficial owner of the dividends is a company that holds directly at least 25% of the capital of the company paying the dividends. The 15% rate applies if the dividends are paid out of income or gains derived directly or indirectly from immovable property and such income or gains from such immovable property is exempted from tax. The 10% rate applies to other dividends.
(q) The tax treaty with Romania entered into force on 4 July 2016 and applies to income derived on or after 1 January 2018.
(r) On 10 March 2014, the SAT released SAT Announcement [2014] No. 16, which announced that the new tax treaty with Ecuador and its protocol, which were signed on 21 January 2013, entered into force on 6 March 2014. The Ecuador treaty and its protocol apply to income derived on or after 1 January 2015. The withholding tax rates under the new treaty are reflected in the table. In addition, the protocol states that the term “interest” also includes other income treated as income from money lent by the tax law of the contracting state in which the income arises if the income is from some type of debt-claim. In the case of divergence of interpretation, the contracting states must resort to the mutual-agreement procedure.
(s) The 5% rate applies to royalties paid to aircraft and ship leasing businesses. The 7% rate applies to other royalties.
(t) The 4% rate applies to interest paid to banks, insurance companies and other financial institutions. The 10% rate applies to other interest payments.
(u) The 2% rate applies to royalties for the use of, or the right to use, industrial, commercial or scientific equipment. The 10% rate applies to other royalties.
(v) The 5% rate applies if the beneficial owner of the dividends is a company that holds directly at least 25% of the capital, valued at least EUR80,000, of the company paying the dividends. The 10% rate applies to other dividends.
(w) The 2.5% rate applies if the beneficial owner of the dividends is a company that controls directly or indirectly at least 25% of the company paying the dividends. The 7.5% rate applies to other dividends.
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