Investment In Greece - Treaty Withholding Rates

KP
KPMG Peat Marwick Kyriacou

Contributor

KPMG Peat Marwick Kyriacou
Greece Accounting and Audit
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TREATY WITHHOLDING RATES (Interest, Dividends and Royalties)

RESIDENT OF        INTEREST       DIVIDENDS       ROYALTIES
RECIPIENT

NON-TREATY RATES:  40% Entities      Nil         20% Industrial
                   20% Individuals               10% Film, 
                                                     literary etc.

TREATY RATES: 

Austria              0/10    (b)           (a)        0/10    (b)
Belgium                15            25    (j)           5
Bulgaria               10    (i)     40    (i) (j)      10    (i)
Cyprus                 10            25    (j)         0/5    (c)
Czech Republic         10                  (a)          10
Denmark                 8            38    (j)           5
Finland                10            47    (j)          10
France                 10                  (a)           5
Germany                10            25    (j)           0
Hungary                10            45    (j)          10
India                        (a)           (a)                (a)
Italy                  10            15    (j)         0/5    (e)
Luxembourg              8    (h)     38    (h) (j)     5/7    (d) (h)
Netherlands          8/10    (f)     35    (j)         5/7    (d)
Norway                 10            40    (j)          10
Poland                 10                  (a)          10
Romania                10    (h)     45    (j)         5/7    (d) (h)
Slovakia               10                  (a)          10
Sweden                 10                  (a)           5
Switzerland            10            35    (j)           5
United Kingdom          0    (g)           (a)           0    (g)
United States           0    (k)           (a)           0

Notes:

(a) Non-Treaty rates apply.

(b) 10% rate applies where corporations are inter-related, see tax treaty.

(c) 5% rate applies where royalties are for cinematography films other than films shown on television.

(d) 5% rate applies where royalties are for copyright of literary, artistic or scientific work including cinematography films.

(e) Nil rate applies where royalties are for artistic, scientific work and copyright.

(f) 8% withholding tax on interest applies if the beneficiary is a bank or financial institution.

(g) The domestic withholding tax rates apply to interest and royalty payments in excess of fair and reasonable compensation.

(h) For income earned from 1 January 1996.

(i) Not in force yet.

(j) Local rate of nil applies as it is less than treaty rate.

(k) Non-treaty rate applies to interest in excess of 9% annually and where recipient US Corporation has more than 50% interest in Greek paying company.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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